Shareholder Nonrecourse Deductions. Any Shareholder Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Shareholder who bears the economic risk of loss with respect to the Shareholder Nonrecourse Debt to which such Shareholder Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 3 contracts
Samples: Trust Agreement (Compass Group Diversified Holdings LLC), Fourth Amendment (Compass Diversified Holdings), Third Amendment (Compass Group Diversified Holdings LLC)
Shareholder Nonrecourse Deductions. Any Shareholder Nonrecourse Deductions for any Allocation Fiscal Year or other period shall be specially allocated to the Shareholder who bears the economic risk of loss with respect to the Shareholder Nonrecourse Debt to which such Shareholder Nonrecourse Deductions are attributable in accordance with U.S. Treasury Regulations Section 1.704-2(i)(12(i).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (MDB Capital Holdings, LLC), Limited Liability Company Agreement (Cifc LLC), Limited Liability Company Agreement (JMP Group LLC)
Shareholder Nonrecourse Deductions. Any Shareholder Nonrecourse Deductions for any Allocation Fiscal Year shall be specially allocated to the Shareholder who bears the economic risk of loss with respect to the Shareholder Nonrecourse Debt to which such Shareholder Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Shareholder Nonrecourse Deductions. Any Shareholder Nonrecourse Deductions for any Allocation Fiscal Year or other period shall be specially allocated to the Shareholder who bears the economic risk of loss with respect to the Shareholder Nonrecourse Debt to which such Shareholder Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(11.7042(i)(1).
Appears in 1 contract
Samples: Operating Agreement (Northern Technologies International Corp)
