Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 53 contracts
Samples: Operating Agreement (Falcon's Beyond Global, Inc.), Limited Liability Company Agreement (TKO Group Holdings, Inc.), Operating Agreement (Clear Secure, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss as set forth in Treasury Regulations Section 1.752-2 with respect to the Member Nonrecourse Debt to which such Debt. If more than one Member bears the economic risk of loss for a Member Nonrecourse Debt, any Member Nonrecourse Deductions are attributable to that Member Nonrecourse Debt shall be allocated among the Members according to the ratio in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)which they bear the economic risk of loss.
Appears in 26 contracts
Samples: Limited Liability Company Agreement (Cottonwood Multifamily Opportunity Fund, Inc.), Limited Liability Company Agreement (Vivakor, Inc.), Limited Liability Company Agreement (Vivakor, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 22 contracts
Samples: LLC Operating Agreement (Endexx Corp), LLC Operating Agreement (Endexx Corp), Limited Liability Company Operating Agreement
Member Nonrecourse Deductions. Any All Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss under Regulations Section 1.752-2 with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)attributable.
Appears in 18 contracts
Samples: Operating Agreement (Medcath Corp), Operating Agreement (Medcath Corp), Operating Agreement (Medcath Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 13 contracts
Samples: Operating Agreement (TASCR Ventures, LLC), Limited Liability Company Agreement (Federal National Mortgage Association Fannie Mae), Limited Liability Company Agreement (Federal Home Loan Mortgage Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss (within the meaning of Treas. Reg. § 1.752-2) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Treas. Reg. § 1.704-2(i)(1) and 1.704-2(j)(12(i)(l).
Appears in 13 contracts
Samples: Limited Liability Company Agreement (Zeo Energy Corp.), Limited Liability Company Agreement (GEN Restaurant Group, Inc.), Letter Agreement (ESGEN Acquisition Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(12(b)(4) and 1.704-2(j)(12(i)(2).
Appears in 11 contracts
Samples: Limited Liability Company Agreement (Sunstone Hotel Investors, Inc.), Limited Liability Company Agreement (Sunstone Hotel Investors, Inc.), Limited Liability Company Agreement (Sunstone Hotel Investors, Inc.)
Member Nonrecourse Deductions. Any All Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss under Treasury Regulations § 1.752-2 with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)attributable.
Appears in 11 contracts
Samples: Limited Liability Company Agreement (Learn SPAC HoldCo, Inc.), Series 2 Unit Purchase Agreement (Learn SPAC HoldCo, Inc.), Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Member(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 11 contracts
Samples: Limited Liability Company Agreement (Hcp, Inc.), Limited Liability Company Agreement (Hcp, Inc.), Limited Liability Company Agreement (Health Care Property Investors Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member Members who bears bear the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1)of the Treasury Regulations.
Appears in 8 contracts
Samples: Limited Liability Company Operating Agreement, www.sec.gov, Limited Liability Company Operating Agreement (Gmac LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(12(b)(4) and 1.704-2(j)(12(i).
Appears in 8 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Clipper Realty Inc.), Limited Liability Company Agreement (Clipper Realty Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 8 contracts
Samples: Operating Agreement, Operating Agreement (Bluerock Residential Growth REIT, Inc.), Operating Agreement (Bluerock Residential Growth REIT, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(12(b)(4) and 1.704-2(j)(12(i).
Appears in 8 contracts
Samples: Limited Liability Company Agreement (Welltower OP LLC), Operating Agreement (StartEngine Real Estate REIT 1 LLC), Operating Agreement (Broadstone Net Lease, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt or other liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(12(i) and Regulations Section 1.704-2(j)(11(b).
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Time Warner Cable Information Services (Texas), LLC), Operating Agreement (Sterling Construction Co Inc), Limited Liability Company Agreement (Wright Investors Service Holdings, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 7 contracts
Samples: Operating Agreement (Us Xpress Enterprises Inc), Operating Agreement (Hunt J B Transport Services Inc), Operating Agreement (Werner Enterprises Inc)
Member Nonrecourse Deductions. Any In accordance with the principles set forth in Treasury Regulations Section 1.704-2(i), any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears Members in accordance with the ratios in which they potentially bear the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)Debt.
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Penske Automotive Group, Inc.), Limited Liability Company Agreement (United Auto Group Inc), Limited Liability Company Agreement (United Auto Group Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1)of the Regulations.
Appears in 6 contracts
Samples: Limited Liability Company Operating Agreement (Decrane Holdings Co), Limited Liability Company Operating Agreement (Decrane Aircraft Holdings Inc), Limited Liability Company Operating Agreement (Decrane Aircraft Holdings Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year of the LLC or other period shall be specially allocated to the Member who bears (or is deemed to bear) the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i)(2).
Appears in 6 contracts
Samples: Limited Liability Company Operating Agreement (Emvelco Corp.), Limited Liability Company Operating Agreement (Euroweb International Corp), Limited Liability Company Operating Agreement (Euroweb International Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 6 contracts
Samples: Limited Liability Company Agreement (CNL Healthcare Properties, Inc.), Limited Liability Company Agreement (CNL Healthcare Properties, Inc.), Limited Liability Company Agreement (CNL Healthcare Properties, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections § 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 6 contracts
Samples: Limited Liability Company Agreement (Carlyle Secured Lending, Inc.), Limited Liability Company Agreement (TCG Bdc, Inc.), Limited Liability Company Agreement
Member Nonrecourse Deductions. Any Member The Members Nonrecourse Deductions for any Fiscal Year of the Company shall be specially allocated to the Member who that bears the economic risk of loss with respect to for such deductions within the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury meaning of Regulations Sections 1.704-2(i)(1) and 1.752-2 and otherwise as provided in Regulations Section 1.704-2(j)(12(i).
Appears in 6 contracts
Samples: Limited Liability Company Operating Agreement, Limited Liability Company Operating Agreement (Carey Watermark Investors Inc), Limited Liability Company Operating Agreement (Carey Watermark Investors Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated allocated, in accordance with Regulations Section 1.704-2(i)(l), to the Member or Members who bears bear the economic risk of loss with respect to for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)attributable.
Appears in 5 contracts
Samples: Letter Agreement (Bioceres S.A.), Letter Agreement (Bioceres S.A.), Letter Agreement (Bioceres S.A.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated allocated, in accordance with Regulations Section 1.704-2(i)(1), to the Member or Members who bears bear the economic risk of loss with respect to for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)attributable.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Grom Social Enterprises, Inc.), Operating Agreement (MVP REIT II, Inc.), Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Carramerica Realty Corp), Limited Liability Company Agreement (Columbia Equity Trust, Inc.), Limited Liability Company Agreement (REITPlus, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 5 contracts
Samples: Operating Agreement (Norhart Invest LLC), Limited Liability Company Agreement (Celadon Group Inc), Limited Liability Company Agreement (GoDaddy Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears (or is deemed to bear) the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i)(2).
Appears in 5 contracts
Samples: Operating Agreement, Operating Agreement (Carlyle Real Estate LTD Partnership Xiv /Il/), Agreement (Carlyle Real Estate LTD Partnership Xv)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1)of the Treasury Regulations.
Appears in 5 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement (Husker Ag LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk Economic Risk of loss Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Vornado Operating Co), Investor Rights Agreement (Mp3 Com Inc), Investor Rights Agreement (Mp3 Com Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1)of the Treasury Regulations.
Appears in 4 contracts
Samples: Operating Agreement (Xethanol Corp), Limited Liability Company Agreement (Lazare Kaplan International Inc), Limited Liability Company Agreement (Lazare Kaplan International Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or portion thereof shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Sections §1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 4 contracts
Samples: Operating Agreement (Columbia Equity Trust, Inc.), Operating Agreement (Columbia Equity Trust, Inc.), Operating Agreement (Columbia Equity Trust, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Terawulf Inc.), Limited Liability Company Agreement (Terawulf Inc.), Limited Liability Company Agreement (Pacific Ethanol, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 4 contracts
Samples: Operating Agreement (Trinity Place Holdings Inc.), Stock Purchase Agreement (Trinity Place Holdings Inc.), Stock Purchase Agreement (Trinity Place Holdings Inc.)
Member Nonrecourse Deductions. Any Notwithstanding anything to the contrary herein, Member Nonrecourse Deductions for any Fiscal Year each fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Lexington Master Limited Partnership), Limited Liability Company Agreement (Winthrop Realty Trust), Limited Liability Company Agreement (Winthrop Realty Trust)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall Company fiscal year will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such those Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Reg. §1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 4 contracts
Samples: www.sundocumentfilings.com, llcoperatingagreements.org, llcoperatingagreements.org
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears (or is deemed to bear) the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i)(2).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Cnet Inc /De), Company Operating Agreement (Kennedy Wilson Inc), Limited Liability Company Operating Agreement (Tsecrp Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 4 contracts
Samples: Operating Agreement (Wilson Donald R. Jr.), Operating Agreement (SCG Financial Acquisition Corp.), Operating Agreement (Paxson Communications Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions Deduction for any Fiscal Year Company fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 4 contracts
Samples: Operating Agreement (New York Times Co), Operating Agreement (New York Times Co), Registration Rights Agreement (Forest City Enterprises Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 4 contracts
Samples: Operating Agreement, Limited Liability Company Operating Agreement (Ashford Hospitality Trust Inc), Limited Liability Company Operating Agreement (Ashford Hospitality Trust Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Operating Agreement (Sport Haley Inc), Operating Agreement (Westminster Capital Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt nonrecourse liability, as determined and defined under Regulations Section 1.704-2(b)(4), to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1). The items of losses, deductions and Code Section 705(a)(2)(b) and expenditures to be so allocated shall be determined in accordance with Regulations Section 1.704-2(j)(12(j)(1)(ii).
Appears in 3 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Techniclone Corp/De/), Limited Liability Company Agreement (Agritope Inc), Limited Liability Company Agreement (Icos Corp / De)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears (or is deemed to bear) the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Operating Agreement (Aladdin Gaming Holding LLC), Operating Agreement (Aladdin Capital Corp), Operating Agreement (Aladdin Gaming Enterprises Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who that potentially bears the an economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with the principles set forth in Treasury Regulations Sections Regulation Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 3 contracts
Samples: Operating Agreement, Operating Agreement (Autobytel Com Inc), Operating Agreement (Autobytel Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other applicable period with respect to a Member Nonrecourse Debt shall be specially allocated to the Member who that bears the economic risk of loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) and 1.704-2(j)(1of the Treasury Regulations).
Appears in 3 contracts
Samples: Operating Agreement, Operating Agreement (Manning & Napier, Inc.), Operating Agreement (Manning & Napier, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i)(2).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (FXCM Inc.), Limited Liability Company Agreement (Global Brokerage, Inc.), Operating Agreement (Barton Protective Services LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation §1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Limited Liability Company Operating Agreement (Rochdale High Yield Advances Fund LLC), Limited Liability Company Operating Agreement (Rochdale Alternative Total Return Fund LLC), Limited Liability Company Operating Agreement (Rochdale Structured Claims Fixed Income Fund LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member Members who bears bear the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(12(i)(l) and 1.704-2(j)(1)of the Treasury Regulations.
Appears in 3 contracts
Samples: www.sec.gov, Limited Liability Partnership Agreement (Delphi Trade Management, LLC), Limited Liability Partnership Agreement (Delphi Automotive PLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year Period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Company Operating Agreement (SRAM International Corp), Master Transaction Agreement (SRAM International Corp), Limited Liability Company Agreement (Carmike Cinemas Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt Liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections ss. 1.704-2(i)(12(i) and 1.704-2(j)(1)of the Regulations.
Appears in 3 contracts
Samples: Operating Agreement (Juliana Mining Co Inc), Operating Agreement (Juliana Mining Co Inc), Juliana Mining Co Inc
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1)of the Regulations.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (CBL & Associates Limited Partnership), Limited Liability Company Agreement (CBL & Associates Limited Partnership), Limited Liability Company Agreement (CBL & Associates Limited Partnership)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other shorter period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Longview Clinic Operations Company, LLC), Limited Liability Company Agreement (Quorum Health Group Inc), Limited Liability Company Agreement (Quorum Health Group Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Member(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Guaranty Agreement (Healthpeak Properties, Inc.), Limited Liability Company Agreement (Hcp, Inc.), Limited Liability Company Agreement (Hcp, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 3 contracts
Samples: Membership Interest Purchase Agreement (Rhove Real Estate 1, LLC), Membership Interest Purchase Agreement (Rhove Real Estate 1, LLC), Operating Agreement (Rhove Real Estate 1, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections §1.704-2(i)(12(i) and 1.704-2(j)(1(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Inland Diversified Real Estate Trust, Inc.), Limited Liability Company Agreement (Inland Diversified Real Estate Trust, Inc.), Limited Liability Company Agreement (Inland Diversified Real Estate Trust, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (DISH Network CORP), Limited Liability Company Agreement (DISH Network CORP)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member Unit Holder who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Operating Agreement (Universal Outdoor Inc), Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions De- ductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1)of the Treasury Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1Section 1.704- 2(i).
Appears in 2 contracts
Samples: Operating Agreement (Insight Communications Co Inc), Operating Agreement (Insight Communications Co Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt Liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).. (g)
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Mechanical Technology Inc), Limited Liability Company Agreement (Mechanical Technology Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Grape Purchase Agreement (Huneeus Vintners LLC), Grape Purchase Agreement (Constellation Brands, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Contribution Agreement (Inland Western Retail Real Estate Trust Inc), Contribution Agreement (Inland Western Retail Real Estate Trust Inc)
Member Nonrecourse Deductions. Any All Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss under Treasury Regulations Section 1.752-2 with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)attributable.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (EcoReady Corp), Limited Liability Company Agreement (Digital Television Services of Kansas LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse ----------------------------- Deductions for any Fiscal Year shall be specially allocated to the Member Member(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Bre Properties Inc /Md/), Limited Liability Company Agreement (Bre Properties Inc /Md/)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704Section 1 .704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Metropcs Communications Inc), Limited Liability Company Agreement (Metropcs Communications Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Economic Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Bellring Brands, Inc.), Limited Liability Company Agreement (Bellring Brands, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other applicable period with respect to a Member Nonrecourse Debt shall be specially allocated to the Member who that bears the economic risk of loss with respect to the for such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations (as determined under Sections 1.704-2(b)(4) and 1.704-2(i)(1) and 1.704-2(j)(1of the Regulations).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (New York REIT, Inc.), Membership Interest Purchase Agreement (New York REIT, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Reg. Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (At&t Wireless Services Inc), Limited Liability Company Agreement (At&t Wireless Services Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated allocated, in accordance with Regulations § 1.704-2(i)(1), to the Member or Members who bears bear the economic risk of loss with respect to for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)attributable.
Appears in 2 contracts
Samples: Operating Agreement (World Tree Usa, LLC), Operating Agreement (World Tree Usa, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(12(i)(l) and 1.704-2(j)(1)of the Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (CBL & Associates Limited Partnership), Limited Liability Company Agreement (CBL & Associates Limited Partnership)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(12(i) and 1.704-2(j)(1(1).
Appears in 2 contracts
Samples: Contribution Agreement (Inland Western Retail Real Estate Trust Inc), Contribution Agreement (Inland Western Retail Real Estate Trust Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Operating Agreement (IMH Financial Corp), Restated Operating Agreement (IMH Secured Loan Fund, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Majestic Holdco, LLC), Equity Funding Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections section 1.704-2(i)(1) and 1.704-2(j)(1).. ARTICLE XIV
Appears in 2 contracts
Samples: Operating Agreement (Castle Arch Real Estate Investment Company, LLC), Amended Operating Agreement (Castle Arch Real Estate Investment Company, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who that bears the economic risk of loss with for the debt (i.e., the partner nonrecourse debt) in respect to the Member Nonrecourse Debt to of which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations (as determined under Regulation Sections 1.704-2(i)(12(b)(4) and 1.704-2(j)(1(i)(1)).
Appears in 2 contracts
Samples: Operating Agreement (General Growth Properties Inc), Operating Agreement (General Growth Properties Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation Section 1.704-2(i)(1) and 1.704). 112776\000004\4811-2(j)(1).8359-3203v4 Doc ID: c91f21627f893d8e0c88f012967bb67addc1b065
Appears in 2 contracts
Samples: Membership Interest Purchase Agreement (Rhove Real Estate 1, LLC), Operating Agreement (Rhove Real Estate 1, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other relevant period shall be specially allocated to the Member who bears the economic risk of loss (within the meaning of Treas. Reg. § 1.752-2) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Treas. Reg. § 1.704-2(i)(1) and 1.704-2(j)(12(i)(l).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (HNR Acquisition Corp.), Limited Liability Company Agreement (HNR Acquisition Corp.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall fiscal year or other period will be specially allocated to the Member Member, if any, who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Operating Agreement (Life Time Fitness Inc), Operating Agreement (Life Time Fitness Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections § 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (BFC Financial Corp), Stock Purchase Agreement (Bankatlantic Bancorp Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)2(i)(2) of the Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Alcoa Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member Member(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1Section 1.704- 2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Inland Real Estate Corp), Limited Liability Company Agreement (Inland Real Estate Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704ss.1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Prime Medical Services Inc /Tx/), Limited Liability Company Agreement (Prime Medical Services Inc /Tx/)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections ss. 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Hanover Capital Mortgage Holdings Inc), Operating Agreement (Matrix Bancorp Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Nonvoting Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (vTv Therapeutics Inc.), Limited Liability Company Agreement (vTv Therapeutics Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Operating Agreement (Imperium Renewables Inc), Operating Agreement (Shurgard Storage Centers Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections § 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 2 contracts
Samples: Operating Agreement (KonaTel, Inc.), Operating Agreement (US BioEnergy CORP)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Company Agreement (Firepond, Inc.), Company Agreement (FP Tech Holdings, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Dutchess County Cellular Telephone Co Inc), Limited Liability Company Agreement (Dobson Communications Corp)
Member Nonrecourse Deductions. Any In accordance with the principles set forth in Regulations Section 1.704-2(i), any Member Nonrecourse Deductions for any Fiscal Year Period shall be specially allocated to the Member who bears Members in accordance with the ratios in which they potentially bear the economic risk of loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury the Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Fortress Brookdale Acquisition LLC), Limited Liability Company Agreement (Fortress Registered Investment Trust)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Member Member(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable. Such allocations shall be made in accordance with Treasury with, and in the manner set forth in, Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 2 contracts
Samples: Operating Agreement (PERRIGO Co PLC), Operating Agreement (PERRIGO Co PLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation § 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears (or is deemed to bear) the economic risk Economic Risk of loss Loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Regulation section 1.704-2(i)(1) and 1.704-2(j)(12(i)(2).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Secured Principal LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1)the principles of Treas. Reg.
Appears in 1 contract
Samples: Limited Liability Company Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year shall be specially allocated to the Member or Members who bears bear the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 1 contract
Samples: Operating Agreement (Cenex Harvest States Cooperatives)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions nonrecourse deductions for any Fiscal Year fiscal year shall be specially allocated to the Member who bears the economic risk of loss loss, or to the Members in the proportions in which they bear the economic risk of loss, with respect to the Member Nonrecourse Debt nonrecourse debt to which such Member Nonrecourse Deductions nonrecourse deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(1)of the Regulations.
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year a fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i). If more than one Member bears the economic risk of loss with respect to that Member Nonrecourse Debt shall be allocated among the Members based upon the ratio in which they bear the economic risk of loss.
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions nonrecourse deductions (as defined in §§ 1.704-2(i) of the Treasury Regulations) for any Fiscal Year shall will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt nonrecourse debt (as defined in § 1.704-2(b)(4) of the Treasury Regulations) to which such Member Nonrecourse Deductions nonrecourse deductions are attributable in accordance with Treasury Regulations Sections § 1.704-2(i)(12(i) and 1.704-2(j)(1)of the Treasury Regulations.
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Deductions. Any In accordance with the principles set forth in Regulations Section 1.704-2(i), any Member Nonrecourse Deductions for any Fiscal Year fiscal period shall be specially allocated to the Member who bears Members in accordance with the ratios in which they potentially bear the economic risk of loss with respect to the such Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury the Regulations Sections Section 1.704-2(i)(1) and 1.704-2(j)(12(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Finance of America Companies Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year fiscal year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(1).
Appears in 1 contract
Samples: Operating Agreement (Bon-Ton Stores of Lancaster, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(l). "Member Nonrecourse Deductions" has the same meaning as the term "partner non-recourse deductions" set forth in Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(j)(12(1)(2).
Appears in 1 contract
