Distributions of Nonrecourse Liability Proceeds. If, during a taxable year, the LLC makes a distribution to any Member that is allocable to the proceeds of any nonrecourse liability of the LLC that is allocable to an increase in LLC Minimum Gain pursuant to Treasury Regulations Section 1.704-2(h), then the LLC shall elect, to the extent permitted by Treasury Regulations Section 1.704-2(h)(3), to treat such distribution as a distribution that is not allocable to an increase in LLC Minimum Gain.
Appears in 6 contracts
Samples: Operating Agreement (Day One Biopharmaceuticals Holding Co LLC), Operating Agreement (Day One Biopharmaceuticals Holding Co LLC), Operating Agreement (Arvinas Holding Company, LLC)
Distributions of Nonrecourse Liability Proceeds. If, during a taxable year, the LLC makes a distribution to any Member that is allocable to the proceeds of any nonrecourse liability of the LLC that is allocable to an increase in LLC Minimum Gain pursuant to Treasury Regulations Regulation Section 1.704-2(h), then the LLC shall elect, to the extent permitted by Treasury Regulations Regulation Section 1.704-2(h)(3), to treat such distribution as a distribution that is not allocable to an increase in LLC Minimum Gain.
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (OM Asset Management PLC), Limited Liability Company Agreement (OM Asset Management LTD)
Distributions of Nonrecourse Liability Proceeds. If, during a taxable year, the LLC Company makes a distribution to any Member that is allocable to the proceeds of any nonrecourse liability of the LLC Company that is allocable to an increase in LLC Company Minimum Gain pursuant to Treasury Regulations Section 1.704-2(h), then the LLC Company shall elect, to the extent permitted by Treasury Regulations Section 1.704-2(h)(3), to treat such distribution as a distribution that is not allocable to an increase in LLC Company Minimum Gain.
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