Allocation of Nonrecourse Debt. For purposes of Treasury Regulations Section 1.752-3(a), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (i) the amount of Partnership Minimum Gain and (ii) the total amount of Nonrecourse Built in Gain shall be allocated among the Members in accordance with their Percentage Interests.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Chatham Lodging Trust), Limited Liability Company Agreement (Chatham Lodging Trust), Limited Liability Company Agreement (Chatham Lodging Trust)
Allocation of Nonrecourse Debt. For purposes of Treasury Regulations Regulation Section 1.752-3(a), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (i) the amount of Partnership Company Minimum Gain and (ii) the total amount of Nonrecourse Built Built-in Gain shall be allocated among 100% to the Members in accordance with their Percentage InterestsTDC Member.
Appears in 2 contracts
Samples: Company Agreement (InfraREIT, Inc.), Company Agreement (InfraREIT, Inc.)
