Member Nonrecourse Debt definition

Member Nonrecourse Debt has the meaning ofpartner nonrecourse debt” set forth in Treasury Regulations Section 1.704-2(b)(4).
Member Nonrecourse Debt has the meaning set forth in Regulations Section 1.704-2(b)(4).
Member Nonrecourse Debt means “partner nonrecourse debt,” as defined in Section 1.704-2(b)(4) of the Regulations.

Examples of Member Nonrecourse Debt in a sentence

  • Those items of Company loss, deduction or Code Section 705(a)(2)(B) expenditures which are attributable to Member Nonrecourse Debt shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt according to Treasury Regulations Section 1.704-2(i).

  • If more than one Member bears the Economic Risk of Loss with respect to a Member Nonrecourse Debt, such Member Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss.

  • Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member 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 Regulation Section 1.704-2(i).

  • Any item of Company loss or expense that is attributable to Member Nonrecourse Debt shall be specially allocated to the Members in the manner in which they share the economic risk of loss (as defined in Regulations Section 1.752-2) for such Member Nonrecourse Debt.

  • Member Nonrecourse Deductions for any taxable period shall be allocated 100% to the Member that bears the “Economic Risk of Loss” (as defined in the Treasury Regulations) 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).


More Definitions of Member Nonrecourse Debt

Member Nonrecourse Debt means “partner nonrecourse debt” as defined in Treasury Regulations Section 1.704-2(b)(4), substituting the term “Company” for the term “partnership” and the term “Member” for the term “partner” as the context requires.
Member Nonrecourse Debt means any nonrecourse debt of the Company for which any Member bears the economic risk of loss in accordance with applicable Treasury Regulations.
Member Nonrecourse Debt has the meaning given to the termpartner nonrecourse debt” in Treas. Reg. § 1.704-2(b)(4).
Member Nonrecourse Debt means a nonrecourse debt of the Company within the meaning of Section 1.704-2(b)(4) of the Treasury Regulations.
Member Nonrecourse Debt means any Company liability with respect to which one or more but not all of the Members or related Persons to one or more but not all of the Members bears the economic risk of loss within the meaning of Regulations Section 1.752-2 as a guarantor, lender or otherwise.
Member Nonrecourse Debt shall have the meaning of "partner nonrecourse debt" as set forth in Treasury Regulations Section 1.704-2(b)(4).
Member Nonrecourse Debt has the meaning set forth in Section 1.704-2(b)(4) of the Regulations.