Excess Nonrecourse Liabilities means excess nonrecourse liabilities within the meaning of Treas. Reg. § 1.752-3(a)(3).

Excess Nonrecourse Liabilities has the meaning set forth in Section 5.4(g).

Excess Nonrecourse Liabilities means excess nonrecourse liabilities within the meaning of Treasury Regulations § 1.752-3(a)(3).

Examples of Excess Nonrecourse Liabilities in a sentence

For the purpose of determining the Members’ shares of the Company’s Excess Nonrecourse Liabilities pursuant to Treas.
Non-Recourse Deductions for any Fiscal Year or other period shall be allocated 99% to the Members in proportion to their Units and 1% to the Managers and each Member’s and the Manager’s share of Excess Non-recourse Liabilities shall be in the same proportion.
Nonrecourse Debts of the Company which constitute Excess Nonrecourse Liabilities shall be allocated among the Members in accordance with their respective Company Interests.
For the purpose of determining the Partners' shares of the Company's Excess Nonrecourse Liabilities pursuant to Treasury Regulations §§ 1.752-3(a)(3) and 1.707-5(a)(2)(ii), and solely for such purpose, the Partners' interests in profits are hereby specified to be their respective distributions for the period in question.
For the purpose of determining the Members' shares of the Company's Excess Nonrecourse Liabilities pursuant to Treas.

More Definitions of Excess Nonrecourse Liabilities

Excess Nonrecourse Liabilities means the excess of (i) Member Newco's aggregate Nonrecourse Liabilities over (ii) the aggregate amount of such Nonrecourse Liabilities allocable to the Members pursuant to Treas. Reg. 1.752-3(a)(1) (relating to the Members' shares of Member Newco Minimum Gain) and Treas. Reg. 1.752-3(a)(2) (relating to allocations of taxable gain under Section 4.02 of this Exhibit).

Excess Nonrecourse Liabilities shall have the meaning set forth in Section 5.6 hereof.

Excess Nonrecourse Liabilities. Solely for purposes of determining a Member's proportionate share of the "excess nonrecourse liabilities" of the Company within the meaning of Section 1.752-3(a)(3) of the Regulations, the Members' interests in the Company's Profits are in proportion to their LLC Percentages.

Excess Nonrecourse Liabilities shall have the meaning set forth in Section 1.752-3(a)(3) of the Treasury Regulations.

Excess Nonrecourse Liabilities has the meaning set forth in Section 1.752-3 of the Regulations.

Excess Nonrecourse Liabilities has the meaning set forth in Regulation § 1.752-3(a)(3) (26 C.F.R. § 1.752-3(a)(3)).

Excess Nonrecourse Liabilities has the same meaning as set forth in Treas. Reg. Section I .752-3(a)(3).