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)
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)
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 (Summa Four Inc)
