Allocation of Member Nonrecourse Deductions. Member Nonrecourse Deductions 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 Section 1.704-2(i)(1) of the Regulations.
Appears in 17 contracts
Samples: Operating Agreement (Mack Cali Realty L P), Operating Agreement (Mack Cali Realty L P), Operating Agreement (Mack Cali Realty L P)
Allocation of Member Nonrecourse Deductions. Member Nonrecourse Deductions specially allocated shall be allocated, as provided in Regulations § 1.704-2(i)(1) to the Member who bears Members in accordance with the ratios in which they bear the economic risk of loss with respect to for the relevant Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Section 1.704for purposes of Regulations § 1.752-2(i)(1) of the Regulations2.
Appears in 3 contracts
Samples: Operating Agreement (Radio One, Inc.), Limited Liability Company Operating Agreement (Radio One Distribution Holdings, LLC), Limited Liability Company Operating Agreement (Radio One Distribution Holdings, LLC)
Allocation of Member Nonrecourse Deductions. Any Member Nonrecourse Deductions specially shall be 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 Regulation Section 1.704-2(i)(1) of the Regulations).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Daimlerchrysler Wholesale Receivables LLC), Daimlerchrysler Wholesale Receivables LLC, Carco Auto Loan Master Trust
Allocation of Member Nonrecourse Deductions. Member Nonrecourse Deductions specially shall be allocated to the Member who bears Members that 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)(1) of the Regulations).
Appears in 1 contract
Allocation of Member Nonrecourse Deductions. Member Nonrecourse Deductions specially shall be allocated to the Member who bears Members as provided in Section 1.704-2(i) of the Regulations in accordance with the ratios in which they bear the economic risk of loss with respect to under Section 1.752-2 of the Regulations for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Regulationsrelate.
Appears in 1 contract
Allocation of Member Nonrecourse Deductions. Member Nonrecourse Deductions (within the meaning of Section 1.704-2(i) of the Regulations) shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt (within the meaning of Section 1.704-2(b)(4) of the Regulations) to which such Member Nonrecourse Deductions are attributable in accordance with Section 1.704-2(i)(1) of the Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Trimedia Entertainment Group Inc)