Allocation of Nonrecourse Deductions. Items of loss, deduction and Code Sec. 705(a)(2)(B) Expenditures attributable under Sec. 1.704-2(c) of the Regulations to increases in the Company’s Minimum Gain shall be allocated, as provided in Sec. 1.704-2(e) of the Regulations, to the Members in accordance with the allocation provisions set forth in Article 5.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Green Plains Partners LP), Limited Liability Company Agreement (Delek Logistics Partners, LP)
Allocation of Nonrecourse Deductions. Items of loss, deduction and Code Sec. Section 705(a)(2)(B) Expenditures attributable attributable, under Sec. Section 1.704-2(c) of the Regulations Treasury Regulations, to increases in the Company’s 's Minimum Gain shall be allocated, as provided in Sec. Section 1.704-2(e) of the Treasury Regulations, to the Members in accordance with the allocation provisions set forth in Article 5their Voting Interests.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Minnesota Corn Processors LLC), Limited Liability Company Agreement (Corn Products International Inc)
Allocation of Nonrecourse Deductions. Items of loss, deduction and Code Sec. Section 705(a)(2)(B) Expenditures attributable attributable, under Sec. Section 1.704-2(c) of the Regulations Treasury Regulations, to increases in the Company’s Minimum Gain shall be allocated, as provided in Sec. Section 1.704-2(e) of the Treasury Regulations, to the Members in accordance with the allocation provisions set forth in Article 5their respective Percentage Interests.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (SS&C Technologies Holdings Inc), Contribution Agreement (Coty Inc.)
Allocation of Nonrecourse Deductions. Items of loss, ------------------------------------ deduction and Code Sec. Section 705(a)(2)(B) Expenditures expenditures attributable under Sec. Section 1.704-2(c) of the Treasury Regulations to increases in the Company’s Company Minimum Gain shall be allocated, as provided in Sec. Section 1.704-2(e) of the Treasury Regulations, to the Members pro rata in accordance with proportion to the allocation provisions set forth in Article 5relative number of Units held by each Member.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Endo Pharma LLC)
Allocation of Nonrecourse Deductions. Items of loss, deduction and Code Sec. or Section 705(a)(2)(B) Expenditures attributable attributable, under Sec. Section 1.704-2(c) of the Regulations Treasury Regulations, to increases in the CompanyLLC’s Minimum Gain for any Fiscal Year or other period shall be specifically allocated, as provided in Sec. Section 1.704-2(e) of the Treasury Regulations, to the Members in accordance with the allocation provisions set forth in Article 5their respective Membership Units.
Appears in 1 contract
Allocation of Nonrecourse Deductions. Items of loss, deduction and Code Sec. Section 705(a)(2)(B) Expenditures attributable attributable, under Sec. Section 1.704-2(c) of the Regulations Treasury Regulations, to increases in the Company’s Partnership Minimum Gain shall be allocated, as provided in Sec. Section 1.704-2(e) of the Treasury Regulations, 1% to the Members in accordance with General Partner and 99% to the allocation provisions set forth in Article 5Class A Limited Partners.
Appears in 1 contract
Samples: Limited Partnership Agreement (ServiceMaster Consumer Services Limited Partnership)
Allocation of Nonrecourse Deductions. Items of loss, deduction and Code Sec. Section 705(a)(2)(B) Expenditures expenditures attributable under Sec. Section 1.704-2(c) of the Treasury Regulations to increases in the Company’s Company Minimum Gain shall be allocated, as provided in Sec. Section 1.704-2(e) of the Treasury Regulations, to the Members pro rata in accordance with proportion to the allocation provisions set forth in Article 5relative number of Units held by each Member.
Appears in 1 contract
Samples: Limited Liability Company Agreement (FanSided Inc.)
