Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §1.704-2(i).
Appears in 5 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §Section 1.704-2(i).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Rouse Properties, Inc.), Limited Liability Company Operating Agreement (Allegheny Energy Inc), Members' Agreement (Stratosphere Corp)
Allocation of Member Nonrecourse Deductions. Notwithstanding ------------------------------------------- any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §(S) 1.704-2(i).
Appears in 2 contracts
Samples: Members Agreement (Ebs Pension LLC), Members Agreement (Ebs Litigation LLC)
Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any Any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall will be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §§ 1.704-2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (NorthStar Asset Management Group Inc.), Unit Purchase Agreement (NorthStar Asset Management Group Inc.)
Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §§ 1.704-2(i).
Appears in 2 contracts
Samples: Operating Agreement (Ak Steel Holding Corp), Limited Liability Partnership Agreement (Micron Technology Inc)
Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §Section 1.704-2(i).. APPENDIX A-6 ACTIVE 203377426v.6
Appears in 1 contract
Samples: Limited Liability Company Agreement (Rouse Properties, Inc.)
Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §Section 1.704-2(i).. 6
Appears in 1 contract
Samples: Members Agreement (Ebs Building LLC)
Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §Section 1.704-2(i).. APPENDIX A-6 ACTIVE 202923160v.13
Appears in 1 contract
Samples: Limited Liability Company Agreement (Rouse Properties, Inc.)
Allocation of Member Nonrecourse Deductions. Notwithstanding any other provisions of the this Agreement, any item of Member Nonrecourse Deduction with respect to a Member Nonrecourse Debt shall will be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treas. Reg. §§ 1.704-2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (NorthStar Asset Management Group Inc.)
