Common use of Allocations of Nonrecourse Deductions and Minimum Gain Clause in Contracts

Allocations of Nonrecourse Deductions and Minimum Gain. Notwithstanding the provisions of Section 5.01, if at any time the LLC incurs any “nonrecourse debt” (i.e., debt that is treated as nonrecourse for purposes of Treasury Regulation Section 1.1001-2), the following provisions will apply notwithstanding anything to the contrary expressed elsewhere in this Agreement:

Appears in 3 contracts

Samples: Limited Liability Company Agreement (Cmgi Inc), Limited Liability Company Agreement (Cmgi Inc), Limited Liability Company Agreement (Cmgi Inc)

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Allocations of Nonrecourse Deductions and Minimum Gain. Notwithstanding the provisions of Section 5.01, if at any time the LLC incurs any "nonrecourse debt" (i.e., i.e. debt that is treated as nonrecourse for purposes of Treasury Regulation Section 1.1001-2), the following provisions will apply notwithstanding anything to the contrary expressed elsewhere in this Agreement:

Appears in 2 contracts

Samples: Limited Liability Company Agreement (Cmgi Inc), Limited Liability Company Agreement (Cmgi Inc)

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Allocations of Nonrecourse Deductions and Minimum Gain. Notwithstanding the provisions of Section 5.012.07 above, if at any time the LLC incurs any "nonrecourse debt" (i.e., i.e. debt that is treated as nonrecourse for purposes of Treasury Regulation Section 1.1001-2), the following provisions will apply notwithstanding anything to the contrary expressed elsewhere in this Agreement:

Appears in 1 contract

Samples: Operating Agreement of Summation (Summa Four Inc)

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