Additional Allocations. (a) Allocation of Member Nonrecourse Deductions When Member Bears Economic Risk of Loss. Notwithstanding the provisions of Section 5.1 and subject to the provisions of Section 5.2(c), items of loss and deduction and Section 705(a)(2)(B) Expenditures attributable, under Treasury Regulation Section 1.704-2(i), to Member Nonrecourse Debt shall be allocated to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt (as determined pursuant to Treasury Regulation Section 1.752-3).
Appears in 5 contracts
Samples: Operating Agreement (Oxbow Fund LLC), Operating Agreement (Oxbow Fund LLC), Operating Agreement (Oxbow Fund LLC)