Member Nonrecourse Deductions. If there are any “partner nonrecourse deductions” (within the meaning of Section 1.704-2(i)(1) of the Treasury Regulations) in an Allocation Year, then such deductions will be allocated to the Member who bears the economic risk of loss for the “partner nonrecourse liability” (within the meaning of Section 1.704-2(b)(4) of the Treasury Regulations) to which the deductions are attributable.
Appears in 4 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement (Delek Logistics Partners, LP)
Member Nonrecourse Deductions. If there are any “partner nonrecourse deductions” (within the meaning of Treasury Regulation Section 1.704-2(i)(1) of the Treasury Regulations)) in an Allocation Yeara fiscal year, then such deductions will shall be allocated to the Member who that bears the economic risk of loss for the “partner nonrecourse liability” (within the meaning of Treasury Regulation Section 1.704-2(b)(4) of the Treasury Regulations)) to which the deductions are attributable.
Appears in 4 contracts
Samples: Contribution Agreement (American Midstream Partners, LP), Limited Liability Company Agreement (American Midstream Partners, LP), Limited Liability Company Agreement
Member Nonrecourse Deductions. If there are any “partner nonrecourse deductions” (within the meaning of Section 1.704-2(i)(1) of the Treasury Regulations) in an Allocation a Fiscal Year, then such deductions will be allocated to the Member who bears the economic risk of loss for the “partner nonrecourse liability” (within the meaning of Section 1.704-2(b)(4) of the Treasury Regulations) to which the deductions are attributable.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Federated National Holding Co), Limited Liability Company Agreement (Intrexon Corp), Contribution and Formation Agreement (Cousins Properties Inc)
Member Nonrecourse Deductions. If there are any “Any partner nonrecourse deductions” deductions (within the meaning of Section as defined in Treasury Regulations §§ 1.704-2(i)(1) of the Treasury Regulationsand 1.704-2(i)(2)) in an Allocation Year, then such deductions will for any fiscal year shall be specially allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liability” debt (within the meaning of Section as defined in Treasury Regulations § 1.704-2(b)(4) of the Treasury Regulations)) to which the such Member nonrecourse deductions are attributableattributable in accordance with Treasury Regulations § 1.704-2(i)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Cadiz Inc), Limited Liability Company Agreement (Par Petroleum Corp/Co), Limited Liability Company Agreement (Delta Petroleum Corp/Co)
Member Nonrecourse Deductions. If there are any “partner nonrecourse deductions” (within the meaning of Section 1.704-2(i)(1) of the Treasury Regulations) in an Allocation a Fiscal Year, then such deductions will be allocated to the Member who bears the economic risk of loss for the “partner nonrecourse liability” (within the meaning of Section 1.704-2(b)(4) of the Treasury Regulations) to which the deductions are attributable.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Exco Resources Inc), Limited Liability Company Agreement (Exco Resources Inc)
Member Nonrecourse Deductions. If there are any Any “partner nonrecourse deductions” (within the meaning of as defined in Treasury Regulation Section 1.704-2(i)(12(i) of the Treasury Regulations) in an Allocation Year, then such deductions will for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss for the “partner nonrecourse liability” (within the meaning of Treasury Regulation Section 1.752-2) with respect to the partner nonrecourse debt (as such term is defined in Treasury Regulation Section 1.704-2(b)(4) of the Treasury Regulations)) to which the such partner nonrecourse deductions are attributable.attributable in accordance with Treasury Regulation Section 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (MMA Capital Holdings, Inc.), Limited Liability Company Operating Agreement (MMA Capital Holdings, Inc.)
Member Nonrecourse Deductions. If there are any Any “partner nonrecourse deductions” (within the meaning of Section as defined in Treasury Regulations § 1.704-2(i)(1)) of the Treasury Regulations) in an Allocation Year, then such deductions will for any Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liabilitydebt” (within the meaning of Section as defined in Treasury Regulations § 1.704-2(b)(4) of the Treasury Regulations)) to which the such partner nonrecourse deductions are attributableattributable in accordance with Treasury Regulations §1.704- 2(i)(1).
Appears in 2 contracts
Samples: Membership Interest Purchase Agreement (Red Lion Hotels CORP), Limited Liability Company Agreement (Red Lion Hotels CORP)
Member Nonrecourse Deductions. If there are any “partner nonrecourse deductions” (within the meaning of Treasury Regulation Section 1.704-2(i)(1) of the Treasury Regulations)) in an Allocation Yeara fiscal year, then such deductions will shall be allocated to the Member who that bears the economic risk of loss for the “"partner nonrecourse liability” " (within the meaning of Treasury Regulation Section 1.704-2(b)(4) of the Treasury Regulations)) to which the deductions are attributable.
Appears in 2 contracts
Samples: Contribution Agreement (Southcross Energy Partners, L.P.), Limited Liability Company Agreement (American Midstream Partners, LP)
Member Nonrecourse Deductions. If there are any Any “partner nonrecourse deductions” (within the meaning of as defined in Treasury Regulations Section 1.704-2(i)(1)) of the Treasury Regulations) in an Allocation Year, then such deductions will for any fiscal year or other relevant period shall be specially allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liabilitydebt” (within the meaning of as defined in Treasury Regulations Section 1.704-2(b)(4) of the Treasury Regulations)) to which the such partner nonrecourse deductions are attributableattributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Generation Income Properties, Inc.), Limited Liability Company Agreement (Generation Income Properties, Inc.)
Member Nonrecourse Deductions. If there are any Any Member “partner nonrecourse deductions” (within the meaning of as that term is defined in Treasury Regulations Section 1.704-2(i)(12(i)) of the Treasury Regulations) in an for any Allocation Year, then such deductions Year or other period will be specially allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liabilitydebt” (within the meaning of as that term is defined in Treasury Regulations Section 1.704-2(b)(4) of the Treasury Regulations)) to which the such Member nonrecourse deductions are attributable, in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Exco Resources Inc)
Member Nonrecourse Deductions. If there are any “"partner nonrecourse deductions” " (within the meaning of Regulation Section 1.704-2(i)(1) of the Treasury Regulations)) in an Allocation a Fiscal Year, then such deductions will be allocated to the Member who bears the economic risk of loss for the “"partner nonrecourse liability” " (within the meaning of Regulation Section 1.704-2(b)(4) of the Treasury Regulations)) to which the deductions are attributable.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Arris Group Inc), Limited Liability Company Agreement (Nortel Networks Corp)
Member Nonrecourse Deductions. If there are any “Any partner nonrecourse deductions” deductions (within the meaning of as defined in Treasury Regulations Section 1.704-2(i)(11.704 2(i)(2)) of the Treasury Regulations) in an Allocation Year, then such deductions will for each Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liability” debt (within the meaning of as defined in Treasury Regulations Section 1.704-1.704 2(b)(4) of the Treasury Regulations)) to which the such partner nonrecourse deductions are attributable.attributable in accordance with Treasury Regulations Section 1.704 2(i); and
Appears in 1 contract
Samples: Limited Liability Company Agreement (Patriot Transportation Holding Inc)
Member Nonrecourse Deductions. If there are any “Any partner nonrecourse deductions” deductions (within the meaning of as defined according to Treasury Regulation Section 1.704-2(i)(12(i)) of the Treasury Regulations) in an Allocation Year, then such deductions will shall be allocated to the Member who bears the economic risk of loss for with respect to the “Partner Nonrecourse Debt to which such partner nonrecourse liability” (within the meaning of deductions are attributable in accordance with Treasury Regulation Section 1.704-2(b)(4) of the Treasury Regulations) to which the deductions are attributable2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Centerpoint Properties Trust)
Member Nonrecourse Deductions. If there are any “Any partner nonrecourse deductions” non-recourse deductions (within the meaning of Section as defined in Treasury Regulations §1.704-2(i)(12(i)(l) of the Treasury Regulationsand §1.704-2(i)(2)) in an Allocation Year, then such deductions will for any fiscal year shall be specially allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liability” debt (within the meaning of Section as defined in Treasury Regulations §1.704-2(b)(4) of the Treasury Regulations)) to which the such Member nonrecourse deductions are attributableattributable in accordance with Treasury Regulations §l.704-2(i)(l).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Member Nonrecourse Deductions. If there are any “partner Partner nonrecourse deductions” (within the meaning of as defined in Treasury Regulations Section 1.704-2(i)(1) of the Treasury Regulationsand (2)) in an Allocation Year, then such deductions will for any Fiscal Year or other applicable period shall be specially allocated to the Member who that bears the economic risk of loss for the “partner nonrecourse liabilitydebt” (within the meaning of as defined in Treasury Regulations Section 1.704-2(b)(4)) in respect of the which such Member Nonrecourse Deductions are attributable (as determined under Treasury RegulationsRegulations Sections 1.704-2(b)(4) to which the deductions are attributableand (i)(1)).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Helios & Matheson Analytics Inc.)
Member Nonrecourse Deductions. If there are any Any “partner nonrecourse deductions” (within the meaning of as defined in Treasury Regulations Section 1.704-2(i)(12(i)) of the Treasury Regulations) in an Allocation Year, then such deductions will for any fiscal year or other period shall be allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liability” (within the meaning of debt to which such partner nonrecourse deductions are attributable in accordance with Treasury Regulations Section 1.704-2(b)(4) of the Treasury Regulations) to which the deductions are attributable2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Clean Energy Fuels Corp.)
Member Nonrecourse Deductions. If there are any Any “partner nonrecourse deductions” (within the meaning of as defined in Treasury Regulation Section 1.704-2(i)(12(i) of the Treasury Regulations) in an Allocation Year, then such deductions will for any Fiscal Year or other period shall be specially allocated to the Member who bears the economic risk of loss for the “partner nonrecourse liability” (within the meaning of Treasury Regulation Section 1.752-2) with respect to the partner nonrecourse debt (as such term is defined in Treasury Regulation Section 1.704-2(b)(4) of the Treasury Regulations)) to which the such partner nonrecourse deductions are attributableattributable in accordance with Treasury Regulation Section 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Mma Capital Management, LLC)
Member Nonrecourse Deductions. If there are any Any “partner nonrecourse deductions” (within the meaning of Treasury Regulation Section 1.704-2(i)(12(i)(2)) of the Treasury Regulations) in an Allocation Year, then such deductions will will be allocated allocated to the Member who that bears the economic risk of loss for the “partner nonrecourse liability” (within the meaning of Section Member nonrecourse debt to which such deductions relate as provided in Treasury Regulation Section 1.704-2(b)(4) of the Treasury Regulations) to which the deductions are attributable.2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (CQENS Technologies Inc.)
Member Nonrecourse Deductions. If there are any “Any "partner nonrecourse deductions” (within the meaning of deduction," as defined in Treasury Regulations Section 1.704-2(i)(1) of the Treasury Regulationsand (2) in an Allocation Yearfor any fiscal year, then such deductions will shall be specially allocated to the Member who bears or the Members in the ratio in which such Member or the Members bear the economic risk of loss for with respect to the “"partner nonrecourse liability” debt" of the Company (within the meaning of as defined in Treasury Regulations Section 1.704-2(b)(4) of the Treasury Regulations)) to which the such partner nonrecourse deductions are attributableattributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Deductions. If there are any “Any partner nonrecourse deductions” deductions (within the meaning of as defined in Treasury Regulations Section 1.704-2(i)(12(i)(2)) of the Treasury Regulations) in an Allocation Year, then such deductions will for each Fiscal Year shall be specially allocated to the Member who bears the economic risk of loss for with respect to the “partner nonrecourse liability” debt (within the meaning of as defined in Treasury Regulations Section 1.704-2(b)(4) of the Treasury Regulations)) to which the such partner nonrecourse deductions are attributable.attributable in accordance with Treasury Regulations Section 1.704-2(i); and
Appears in 1 contract
Samples: Limited Liability Company Agreement (Patriot Transportation Holding Inc)
Member Nonrecourse Deductions. If there are any “Any "partner nonrecourse deductions” " (within the meaning of as defined in Treasury Regulations Section 1.704l .704-2(i)(12(i)(l)) of the Treasury Regulations) in an Allocation Year, then such deductions will for any fiscal year or other relevant period shall be specially allocated to the Member who bears the economic risk of loss for with respect to the “"partner nonrecourse liability” debt" (within the meaning of as defined in Treasury Regulations Section 1.704- 2(b)(4)) to which such partner nonrecourse deductions are attributable in accordance with Treasury Regulations Section 1.704-2(b)(4) of the Treasury Regulations) to which the deductions are attributable2(i)(l).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Generation Income Properties, Inc.)