Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means an amount, with respect each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).
Appears in 5 contracts
Samples: Limited Liability Company Operating Agreement (Carey Watermark Investors Inc), Limited Liability Company Operating Agreement (Carey Watermark Investors Inc), Limited Liability Company Operating Agreement (Carey Watermark Investors Inc)
Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means shall mean an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with the provisions of Regulations Section 1.704-2(i)(3)) relating to “partner Nonrecourse Debt minimum gain.”
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Penske Automotive Group, Inc.), Limited Liability Company Agreement (Penske Automotive Group, Inc.), Limited Liability Company Agreement (Penske Automotive Group, Inc.)
Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means an An amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Treasury Regulations Section §1.704-2(i)(32(i)(2) and (3).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Inland Diversified Real Estate Trust, Inc.), Limited Liability Company Agreement (Inland Diversified Real Estate Trust, Inc.)
Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” " means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).
Appears in 2 contracts
Samples: Operating Agreement, Operating Agreement (Wynn Resorts LTD)
Member Nonrecourse Debt Minimum Gain. “Such term shall mean an amount with respect to each Member Nonrecourse Debt Minimum Gain” means an amount, with respect each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3)) of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Envirokare Tech Inc)
Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means shall mean an amount, with respect to each Member Nonrecourse Debt, equal to determined in the Company Minimum Gain that would result if such Member same manner as “Partner Nonrecourse Debt were treated as a Nonrecourse Liability, Minimum Gain” would be determined in accordance with Regulations Section 1.704-2(i)(3)2(i) of the Treasury Regulations.
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Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3)) of the Regulations, determined after substituting the word “Member” for the word “Partner” therein.
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means an An amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-1.704 2(i)(3)) of the Regulations.
Appears in 1 contract
Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means an An amount, with respect to each Member Nonrecourse Debt, equal to the Company LLC Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3)) of the Regulations.
Appears in 1 contract
Member Nonrecourse Debt Minimum Gain. “The amount with respect to each Member Nonrecourse Debt Minimum Gain” means an amount, with respect each Member Nonrecourse Debt, equal to the Limited Liability Company Minimum Gain that would result if such Member Nonrecourse Debt were is treated as a Nonrecourse Liability, liability determined in accordance with Regulations Section 1.704-2(i)(3)) of the Regulations.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Nexcore Healthcare Capital Corp)
Member Nonrecourse Debt Minimum Gain. “Member Nonrecourse Debt Minimum Gain” means an amount, with With respect to each Member Nonrecourse Debt, an amount equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).
Appears in 1 contract
Samples: Limited Liability Company Agreement (American Realty Capital Healthcare Trust Inc)