Member Non-Recourse Deductions. Member Nonrecourse Deductions for any Fiscal Year of the Company shall be allocated to the Members in the same proportion as Profits are allocated under Section 2.1.1, provided that any Member Nonrecourse Deductions for any Fiscal Year or other period shall be allocated to the Member who bears (or is deemed to bear) the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation section 1.704-2(i)(2).
Appears in 8 contracts
Samples: Limited Liability Company Agreement (Mission First Capital LLC), Limited Liability Company Agreement (Mission First Capital LLC), Operating Agreement
Member Non-Recourse Deductions. Member Nonrecourse Deductions for any Fiscal Year year of the Company shall be allocated to the Members in the same proportion as Profits are allocated under Section 2.1.1, provided that any Member Nonrecourse Deductions for any Fiscal Year or other period shall be allocated to the Member who bears (or is deemed to bear) the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulation section 1.704-2(i)(2).
Appears in 8 contracts
Samples: Company Operating Agreement (Gilmore Homes - Gilmore Loans, LLC), Company Operating Agreement (Gilmore Homes - Gilmore Loans, LLC), Company Operating Agreement (Gilmore Homes - Gilmore Loans, LLC)