Allocation of Member Nonrecourse Deductions. Notwithstanding the provisions of Section 5.4, items of loss, deduction and Code Sec. 705(a)(2)(B) Expenditures attributable under Sec. 1.704-2(i) of the Regulations to Member Nonrecourse Debt shall (prior to any allocation pursuant to Section 5.4) be allocated, as provided in Sec. 1.704-2(i) of the Regulations, to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt for purposes of Sec. 1.752-2 of the Regulations.
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Samples: Limited Liability Company Agreement (Green Plains Partners LP), Limited Liability Company Agreement (Delek Logistics Partners, LP)
Allocation of Member Nonrecourse Deductions. Notwithstanding the provisions of Section 5.4, items Items of loss, deduction and Code Sec. or Section 705(a)(2)(B) Expenditures attributable attributable, under Sec. Section 1.704-2(i) of the Regulations Treasury Regulations, to Member Nonrecourse Debt for any Fiscal Year or other period shall (prior to any allocation pursuant to Section 5.4) be specifically allocated, as provided in Sec. 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 Sec. Section 1.752-2 of the Treasury Regulations.
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Allocation of Member Nonrecourse Deductions. Notwithstanding the any other provisions of Section 5.4this Agreement, items of loss, deduction deduction, and Code Sec. IRC §705(a)(2)(B) Expenditures attributable under Sec. §1.704-2(i) of the Regulations to Member Nonrecourse Debt shall (prior to any allocation pursuant to Section 5.4) be allocated, as provided in Sec. §1.704-2(i) of the Regulations, to the Members in accordance with the ratios in which they bear the economic risk of loss for such debt for purposes of Sec. §1.752-2 of the Regulations.
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