Noncompensatory Option definition
Noncompensatory Option has the meaning set forth in Treasury Regulation Section 1.721-2(f).
Noncompensatory Option is defined in Regulations Section 1.721-2(f).
Noncompensatory Option means a “noncompensatory option” within the meaning of Treasury Regulations Sections 1.721-2(f) and 1.761-3(b)(2).
Examples of Noncompensatory Option in a sentence
Any Member who has received its interest pursuant to the exercise of a Noncompensatory Option shall be allocated gain or loss or reallocated capital from other Members’ Capital Accounts as necessary to comply with Treasury Regulation Section 1.704-1(b)(2)(iv)(5).
In determining such Unrealized Gain or Unrealized Loss, the aggregate fair market value of all Company property (including cash or cash equivalents) immediately prior to the issuance of additional Membership Interests (or, in the case of an issuance of a Noncompensatory Option, immediately after such issuance if required pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(s)(1)) shall be determined by the Managing Member using such method of valuation as it may adopt.
More Definitions of Noncompensatory Option
Noncompensatory Option means a “noncompensatory option” within the meaning of Regulations Sections 1.721-2(f) and 1.761-3(b)(2). For purposes of clarification, the Series E Preferred Units, the Series F Preferred Units, the Series G Preferred Units or the Series H Preferred Units shall be treated as Noncompensatory Options.
Noncompensatory Option means a “noncompensatory option” (as defined in Treasury Regulations §§ 1.721-2(f) and 1.761-3(b)(2)) issued by the Company, which, as of the date of such issuance, is not treated as a partnership interest for federal tax purposes pursuant to Treasury Regulations § 1.761-3(a) or otherwise pursuant to general principles of federal tax law, in all respects as determined by the Board of Managers.
Noncompensatory Option means a “noncompensatory option” within the meaning of Regulations Sections 1.721-2(f) and 1.761-3(b)(2). For purposes of clarification, the conversion feature of the Series A Preferred Units shall be treated as Noncompensatory Options.
Noncompensatory Option means a “noncompensatory option” within the meaning of Regulations Sections 1.721-2(f) and 1.761-3(b)(2). “Nonrecourse Deductions” has the meaning set forth in Regulations Section 1.704-2(b)(1), and the amount of Nonrecourse Deductions for a
Noncompensatory Option has the meaning set forth in Treasury Regulation Section 1.721-2(f). “Nonrecourse Built-in Gain” means with respect to any Contributed Properties or Adjusted Properties that are subject to a mortgage or pledge securing a Nonrecourse Liability, the amount of any taxable gain that would be allocated to the Partners pursuant to Sections 6.2(b)(i)(A), 6.2(b)(ii)(A) and 6.2(b)(iii) if such properties were disposed of in a taxable transaction in full satisfaction of such liabilities and for no other consideration.
Noncompensatory Option means a “noncompensatory option” within the meaning of Treasury Regulation Sections 1.721- 2(f) and 1.761-3(b)(2) issued by the Partnership which, as of the date such option is issued by the Partnership, is not treated as a partnership interest pursuant to Treasury Regulation Section 1.761-3(a).
Noncompensatory Option has the meaning set forth in Treasury Regulations Section 1.721-2(f). “Nonrecourse Deductions” has the meaning assigned to that term in Treasury Regulations Section 1.704-2(b).