Common use of Allocation of Member Nonrecourse Deductions Clause in Contracts

Allocation of Member Nonrecourse Deductions. Notwithstanding the provisions of Sections 5.1 through 5.5, items of loss, deduction and Section 705(a)(2)(B) Expenditures attributable, under Section 1.704-2(i) of the Treasury Regulations, to Member Nonrecourse Debt shall (prior to any allocation pursuant to Sections 5.1 through 5.5) be allocated, as provided in Section 1.704-2(i) of the Treasury Regulations, to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt for purposes of Section 1.752-2 of the Treasury Regulations.

Appears in 2 contracts

Samples: Limited Liability Company Agreement (Corn Products International Inc), Limited Liability Company Agreement (Minnesota Corn Processors LLC)

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Allocation of Member Nonrecourse Deductions. Notwithstanding the provisions of Sections 5.1 through 5.5and 5.2, items of loss, deduction and Section 705(a)(2)(B) Expenditures attributable, under Section 1.704-2(i) of the Treasury Regulations, to Member Nonrecourse Debt shall (prior to any allocation pursuant to Sections Section 5.1 through 5.5or 5.2) be allocated, as provided in Section 1.704-2(i) of the Treasury Regulations, to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt for purposes of Section 1.752-2 of the Treasury Regulations.

Appears in 1 contract

Samples: Limited Liability Company Agreement (SS&C Technologies Holdings Inc)

Allocation of Member Nonrecourse Deductions. Notwithstanding the provisions of Sections 5.1 through 5.5Section 6.7 hereof, items of loss, deduction and Section 705(a)(2)(B) Expenditures attributable, expenditures attributable under Section 1.704-2(i) of the Treasury Regulations, Regulations to Member Nonrecourse Debt shall (prior to any allocation pursuant to Sections 5.1 through 5.5Section 6.7 hereof) be allocated, as provided in Section 1.704-2(i) of the Treasury Regulations, to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt for purposes of Section 1.752-2 of the Treasury Regulations.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Endo Pharma LLC)

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Allocation of Member Nonrecourse Deductions. Notwithstanding the provisions of Sections 5.1 through 5.5Section 6.7, items of loss, deduction and Section 705(a)(2)(B) Expenditures attributable, expenditures attributable under Section 1.704-2(i) of the Treasury Regulations, Regulations to Member Nonrecourse Debt shall (prior to any allocation pursuant to Sections 5.1 through 5.5Section 6.7) be allocated, as provided in Section 1.704-2(i) of the Treasury Regulations, to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt for purposes of Section 1.752-2 of the Treasury Regulations.

Appears in 1 contract

Samples: Limited Liability Company Agreement (FanSided Inc.)

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