Common use of Allocation of Deductions Attributable to Member Nonrecourse Liabilities Clause in Contracts

Allocation of Deductions Attributable to Member Nonrecourse Liabilities. Any nonrecourse deductions attributable to a Member Nonrecourse Debt (as defined in Treasury Regulation Section 1.704-2(b)(4)) shall be allocated among the Members that bear the economic risk of loss for such Member Nonrecourse Debt in accordance with the ratios in which such Members share such economic risk of loss and in a manner consistent with Treasury Regulation Sections 1.704-2(i) and 1.704- 2(j).

Appears in 4 contracts

Samples: Operating Agreement (NewBridge Global Ventures, Inc.), Operating Agreement (NewBridge Global Ventures, Inc.), Operating Agreement (NewBridge Global Ventures, Inc.)

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Allocation of Deductions Attributable to Member Nonrecourse Liabilities. Any nonrecourse deductions attributable to a Member Nonrecourse Debt (as defined in Treasury Regulation Section 1.704-2(b)(4)) Liability shall be allocated among the Members that bear the economic risk of loss for such Member Nonrecourse Debt that liability in accordance with the ratios in which such Members share such economic risk of loss and in a manner consistent with Treasury Regulation the requirements of Sections 1.704-2(i2(c), 1.704-2(i)(2) and 1.704- 2(j)1.704-2(j)(1) of the Treasury Regulations.

Appears in 1 contract

Samples: Investment Agreement (Barnes & Noble Inc)

Allocation of Deductions Attributable to Member Nonrecourse Liabilities. Any nonrecourse deductions attributable to a Member Nonrecourse Debt (as defined in Treasury Regulation Section 1.704-2(b)(4)) nonrecourse liability shall be allocated among the Members that bear the economic risk of loss for such Member Nonrecourse Debt nonrecourse liability in accordance with the ratios in which such Members share such economic risk of loss and in a manner consistent with the requirements of Treasury Regulation Sections 'SS''SS' 1.704-2(i2(c), 1.704-2(i)(2) and 1.704- 2(j1.704-2(j)(1).

Appears in 1 contract

Samples: Limited Liability Company Agreement (Time Warner Telecom LLC)

Allocation of Deductions Attributable to Member Nonrecourse Liabilities. Any nonrecourse deductions Nonrecourse Deductions attributable to a Member Nonrecourse Debt (as defined in Treasury Regulation Section 1.704-2(b)(4)) shall be allocated among the Members that bear the economic risk of loss for such Member Nonrecourse Debt in accordance with the ratios in which such Members share such economic risk of loss and in a manner consistent with the requirements of Treasury Regulation Sections 1.704-2(i2(c), 1.704-2(i)(2) and 1.704- 2(j1.704-2(j)(1).

Appears in 1 contract

Samples: Limited Liability Company Agreement (Asbury Automotive Group Inc)

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Allocation of Deductions Attributable to Member Nonrecourse Liabilities. Any nonrecourse deductions attributable to a Member Nonrecourse Debt (as defined in Treasury Regulation Section 1.704-2(b)(4)) Liability shall be allocated among the Members that bear the economic risk of loss for such Member Nonrecourse Debt Liability in accordance with the ratios in which such the Members share such economic risk of loss and in a manner consistent with the requirements of Treasury Regulation Sections 1.704-2(i2(c), 1.704-2(i)(2) and 1.704- 2(j1.704-2(j)(l).

Appears in 1 contract

Samples: Limited Liability Company Agreement (Stilwell Financial Inc)

Allocation of Deductions Attributable to Member Nonrecourse Liabilities. Any nonrecourse deductions attributable to a Member Nonrecourse Debt (as defined in Treasury Regulation Section 1.704-2(b)(4)) Liability shall be allocated among the Members that bear the economic risk of loss for such Member Nonrecourse Debt Liability in accordance with the ratios in which such Members share such economic risk of loss and in a manner consistent with the requirements of Treasury Regulation Sections 'SS' 'SS'1.704-2(c), 1.704-2(i2(i)(2) and 1.704- 2(j1.704-2(j)(1).

Appears in 1 contract

Samples: Limited Liability Company Agreement (Time Warner Telecom LLC)

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