Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(1).
Appears in 55 contracts
Samples: Limited Liability Company Agreement (At&t Inc.), Limited Liability Company Agreement (MCI Income Fund VII, LLC), Limited Liability Company Agreement (MCI Income Fund VII, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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)(1).
Appears in 19 contracts
Samples: Limited Liability Company Agreement (Mid-Con Energy Partners, LP), Limited Liability Company Agreement (Energy Transfer Equity, L.P.), Limited Liability Company Agreement (Williams Companies Inc)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)attributable.
Appears in 14 contracts
Samples: Unitholders Agreement, Unitholders Agreement, Implementation Agreement (Peabody Energy Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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)(1).
Appears in 13 contracts
Samples: Limited Liability Company Agreement (Oasis Petroleum Inc.), Limited Liability Company Agreement (RiverBanc Multifamily Investors, Inc.), Contribution Agreement (RiverBanc Multifamily Investors, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to among the Member Members who bears bear the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Regulations Section 1.704-2(i)(12(b)(4) and (i)(1).
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Vince Holding Corp.), Membership Interest Purchase Agreement (XCel Brands, Inc.), Limited Liability Company Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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)(12(i).
Appears in 7 contracts
Samples: Operating Agreement, Operating Agreement (Air T Inc), Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period 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 Regulations Section 1.704-2(i)(12(i) and Regulations Section 1.704-1(b).
Appears in 6 contracts
Samples: Project Management Agreement (Pinnacle Entertainment Inc), Limited Liability Company Agreement (Charter Communications Inc /Mo/), Limited Liability Company Agreement (Charter Communications Inc /Mo/)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations § 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)attributable.
Appears in 6 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement (CAESARS ENTERTAINMENT Corp)
Member Nonrecourse Deductions. Any Notwithstanding anything to the contrary in this Agreement, any Member Nonrecourse Deductions for any Allocation Fiscal Year shall or other period for which allocations are made will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Regulations Regulation Section 1.704-2(i)(12(i).
Appears in 5 contracts
Samples: Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.), Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.), Operating Agreement (General Automotive Co)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement, Operating Agreement, Limited Liability Company Agreement (Public Service Co of New Hampshire)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year 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 in accordance with Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Motorsport Gaming Us LLC), Limited Liability Company Agreement (Motorsport Gaming Us LLC), Limited Liability Company Agreement (Capitala Finance Corp.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(12(i) (1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Bunge LTD), Operating Agreement (Anworth Mortgage Asset Corp), Operating Agreement (Rock Tenn Co)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(12(i).
Appears in 4 contracts
Samples: Limited Liability Company Operating Agreement (Collins Growth & Income Fund LLC), Limited Liability Company Operating Agreement (Collins Growth & Income Fund LLC), Limited Liability Company Operating Agreement (Collins Growth & Income Fund LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Common 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 Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Oasis Midstream Partners LP), Limited Liability Company Agreement (Oasis Midstream Partners LP), Contribution and Simplification Agreement (Oasis Petroleum Inc.)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Treasury Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)attributable.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Nextracker Inc.), Limited Liability Company Agreement (Nextracker Inc.), Limited Liability Company Agreement (Evolve Transition Infrastructure LP)
Member Nonrecourse Deductions. Any All Member Nonrecourse Deductions for any Allocation Year shall be specially allocated attributable to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which shall be allocated among the Members bearing the Economic Risk of Loss for such Member Nonrecourse Deductions are attributable in accordance debt consistent with Regulations Section 1.704-2(i)(1)) of the Regulations.
Appears in 4 contracts
Samples: Lease Agreement (Skechers Usa Inc), Development Management Agreement (Skechers Usa Inc), Development Management Agreement (Skechers Usa Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for ----------------------------- any Allocation 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 Regulations Section 1.704-2(i)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Forest Bank LLC), Operating Agreement (Finova Group Inc), Limited Liability Company Agreement (Forest Bank LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company 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 attributable, in accordance with Regulations Section 1.704-2(i)(12(i).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Chelsea Gca Realty Inc), Limited Liability Company Agreement (Chelsea Gca Realty Inc), Limited Liability Company Agreement (Chelsea Gca Realty Partnership Lp)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Zentalis Pharmaceuticals, Inc.), Limited Liability Company Agreement (Zentalis Pharmaceuticals, LLC), Limited Liability Company Agreement (Zentalis Pharmaceuticals, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions Deduction for any Allocation Fiscal Year or other period attributable to a Member Nonrecourse Liability shall be specially allocated to the Member Interest Holder who bears the economic risk of loss with respect to for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Regulation Section 1.704-2(i)(12(i).
Appears in 2 contracts
Samples: Operating Agreement (Zoom Technologies Inc), Operating Agreement (Ilx Resorts Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company Year or other applicable 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 Regulations Section Regulation § 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Ashford Hospitality Trust Inc), Limited Liability Company Agreement (Ashford Hospitality Trust Inc)
Member Nonrecourse Deductions. Any Notwithstanding any provision hereof to the contrary, any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Moody National REIT I, Inc.), Limited Liability Company Operating Agreement (Moody National REIT I, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period 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 Section 1.704-2(i)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Mach Natural Resources Lp), Limited Liability Company Agreement (Mach Natural Resources Lp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Treasury Regulation Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (At&t Inc.), Limited Liability Company Agreement (At&t Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Treasury Regulation Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Noble Environmental Power LLC), Limited Liability Company Agreement (Noble Environmental Power LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Member who that bears the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt member nonrecourse debt to which such Member Nonrecourse Deductions are attributable deductions relate as provided in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Employment Agreement (Simon Worldwide Inc), Employment Agreement (Simon Worldwide Inc)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Onconova Therapeutics, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with 21 21 respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-1.704- 2(i)(1).
Appears in 2 contracts
Samples: Operating Agreement (Crescent Operating Inc), Operating Agreement (Crescent Operating Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year taxable 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 Regulations Section 1.704-2(i)(12(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Bluerock Residential Growth REIT, Inc.), Limited Liability Company Agreement (Bluerock Residential Growth REIT, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 in accordance with Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (SFX Entertainment, INC), Limited Liability Company Operating Agreement (Quigley Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company 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 attributable, in accordance with Regulations Section 1.704-2(i)(11.704- 2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (CNL Hospitality Properties Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company Year or other applicable 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 Regulations Section Regulation § 1.704-2(i)(12(i)(l).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Ashford Hospitality Trust Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(11.7042(i)(1).
Appears in 1 contract
Samples: Limited Liability Companyagreement (Majestic Funding Partners, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for ----------------------------- any Allocation 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 Regulations Section 1.704-2(i)(12(i) (1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall Deduction will 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 in accordance with Regulations Section Treasury Regulation § 1.704-2(i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(12(i)(l).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Samples: Operating Agreement (Wells Mid-Horizon Value-Added Fund I LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions (as defined in Section 11(c) hereof) for any Allocation 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 Regulations Section 1.704-2(i)(12(i)(l).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section Treas. Reg. §1.704-2(i)(12(i)(l).
Appears in 1 contract
Samples: Limited Liability Company Agreement (NRG Retail LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 the deductions are attributable allocable in accordance with Regulations Regulation Section 1.704-2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Carter Validus Mission Critical REIT, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Series B Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section § 1.704-2(i)(1).
Appears in 1 contract
Samples: Separate Series Operating Agreement (Rabble One, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(11.704 -2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Global Green Solutions Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall 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 Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year or other period shall be specially allocated to the Member who that bears the economic risk of loss with respect to for the Member Nonrecourse Debt to in respect of which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section (as determined under Regulation Sections 1.704-2(i)(12(b)(4) and (i)(1)).
Appears in 1 contract
Samples: Operating Agreement (General Growth Properties Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 liability to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Regulation Section 1.704-2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Viant Technology Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 the Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i)(l).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Company 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 Section 1.704-2(i)(12(i).
Appears in 1 contract
Samples: T&w Financial Corp
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability to which the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are Deduction is attributable in accordance with Regulations Regulation Section 1.704-2(i)(11.704‑2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 1.704l.704-2(i)(12(i).
Appears in 1 contract
Samples: Operating Agreement (Bespoke Capital Acquisition Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 attributable, in accordance with Regulations Section 1.704-2(i)(1)) of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Main Street Capital CORP)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year year shall be specially allocated to the Member or Members 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 Regulations Section §1.704-2(i)(1).
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (A-Power Energy Generation Systems, Ltd.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section Treas. Reg. §1.704-2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (NRG Retail LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704Treasury Regulation (S)1.704-2(i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Class A Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation § 1.704-2(i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions ----------------------------- for any Allocation 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 Regulations Section 1.704-2(i)(12(i)(2).
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Demattos Carlos D)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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)(11.704‑2(i)(1).
Appears in 1 contract
Samples: Transaction Agreement (Apollo Global Management LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation 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 Regulations Section 1.704-2(i)(1).. (g)
Appears in 1 contract
