Company Nonrecourse Deductions. Company Nonrecourse Deductions (as determined under Treas. Reg. Section 1.704-2(c)) for any fiscal year shall be allocated among the Members in proportion to their Membership Interests.
Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to “partnership nonrecourse liabilities” (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Percentage Interests.
Company Nonrecourse Deductions. Company Nonrecourse Deductions for any year or other period shall be allocated among the Members in accordance with their respective Membership Interests.
Company Nonrecourse Deductions. Company Nonrecourse Deductions for any Company fiscal year shall be specially allocated among the Members in proportion to their Percentage Interests.
Company Nonrecourse Deductions. Nonrecourse deductions that are not related to Member Nonrecourse Debt shall be allocated to the Members in proportion to their respective Ownership Percentages.
Company Nonrecourse Deductions. Nonrecourse Deductions of the Company shall be allocated between the Members in proportion to the Losses or Profits (as the case may be) that are otherwise allocated to the Members pursuant to Section 4.1; provided, however, that in the event such allocation of Nonrecourse Deductions is not reasonably consistent (within the meaning of Regulations Section 1.704-2) with allocations of some other significant Company item attributable to the property securing the related Nonrecourse Debt, the Managers shall have the discretion to make allocations that will satisfy the requirements of such Regulations.
Company Nonrecourse Deductions. Company Nonrecourse Deductions for any taxable period shall be allocated to the Members in accordance with their respective Sharing Ratios. If the Members determine in their good faith discretion that the Company's Nonrecourse Deductions must be allocated in a different ratio to satisfy the safe harbor requirements of the Regulations promulgated under Section 704(b) of the Code, the Members are authorized to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Company Nonrecourse Deductions. Company Nonrecourse Deductions shall be allocated to each Member in accordance with its relative Membership Percentage.
Company Nonrecourse Deductions. Company Nonrecourse Deductions" shall have the meaning set forth in Regulation Section 1.704-2(c), which provides generally that the amount of the Company Nonrecourse Deductions (as identified in Regulation Section 1.704-2(j)(1)(ii)) for a Company fiscal year equals the excess, if any, of the net increase, if any, in the amount of Company Minimum Gain during that fiscal year over the amount of any distributions during that fiscal year of proceeds of a Company Nonrecourse Liability that are allocable to an increase in Company Minimum Gain.
Company Nonrecourse Deductions. The net increase if any, in the amount of Company Minimum Gain during the Taxable Year. The Company Nonrecourse Deductions shall consist first of depreciation or cost recovery deductions with respect to each item of Company Property to the extent of the increase in Company Minimum Gain attributable to Company Nonrecourse Liabilities secured by such Company Property, with the remainder of any Company Nonrecourse Deductions made up of a pro rata portion of the Company's other items of deduction, loss and nondeductible expenditures (to the extent that such nondeductible expenditures reduce Capital Accounts). Company Nonrecourse Deductions shall be further determined in accordance with Regulation ss. 1.704-2(c) and any subsequent rule or regulation governing the determination of Company Nonrecourse Deductions.
