Member Nonrecourse Debt Minimum Gain. In the event that there is a net decrease in Member Nonrecourse Debt Minimum Gain for a taxable year of the Company, then after taking into account allocations pursuant to paragraph (a) immediately preceding, but before any other allocations are made for such taxable year, each Member with a share of Member Nonrecourse Debt Minimum Gain at the beginning of such year shall be allocated items of Book income and gain for such year (and, if necessary, for subsequent years) to the extent required by Treas. Reg. §1.704-2(i)(4).
Appears in 5 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Member Nonrecourse Debt Minimum Gain. In the event that there is a net decrease in Member Nonrecourse Debt Minimum Gain for a taxable year of the Company, then after taking into account allocations pursuant to paragraph (a) immediately preceding, but before any other allocations are made for such taxable year, each Member with a share of Member Nonrecourse Debt Minimum Gain at the beginning of such year shall be allocated items of Book income and gain for such year (and, if necessary, for subsequent years) to the extent required by Treas. Reg. §Section 1.704-2(i)(42(i) (4).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Rouse Properties, Inc.), Limited Liability Company Agreement (Rouse Properties, Inc.), Limited Liability Company Agreement (Rouse Properties, Inc.)
Member Nonrecourse Debt Minimum Gain. In the event that If there is a net decrease in Member Nonrecourse Debt Minimum Gain for a taxable year Tax Year of the Company, then after taking into account allocations pursuant to paragraph (ai) immediately preceding, but before any other allocations are made for such taxable yearTax Year, each Member with a share of Member Nonrecourse Debt Minimum Gain at the beginning of such year shall will be allocated items of Book income and gain for such year (and, if necessary, for subsequent years) to the extent required by Treas. Reg. §§ 1.704-2(i)(4).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (NorthStar Asset Management Group Inc.), Limited Liability Company Agreement (NorthStar Asset Management Group Inc.), Unit Purchase Agreement (NorthStar Asset Management Group Inc.)
Member Nonrecourse Debt Minimum Gain. In the event that there is ------------------------------------ a net decrease in Member Nonrecourse Debt Minimum Gain for a taxable year of the Company, then after taking into account allocations pursuant to paragraph (a) immediately preceding, but before any other allocations are made for such taxable year, each Member with a share of Member Nonrecourse Debt Minimum Gain at the beginning of such year shall be allocated items of Book income and gain for such year (and, if necessary, for subsequent years) to the extent required by Treas. Reg. §(S) 1.704-2(i)(4).
Appears in 2 contracts
Samples: Members Agreement (Ebs Pension LLC), Members Agreement (Ebs Litigation LLC)
Member Nonrecourse Debt Minimum Gain. In the event that there is a net decrease in Member Nonrecourse Debt Minimum Gain for a taxable year of the Company, then after taking into account allocations pursuant to paragraph (a) immediately preceding, but before any other allocations are made for such taxable year, each Member with a share of Member Nonrecourse Debt Minimum Gain at the beginning of such year shall be allocated items of Book income and gain for such year (and, if necessary, for subsequent years) to the extent required by Treas. Reg. §Section 1.704-2(i)(4).
Appears in 2 contracts
Samples: Members' Agreement (Stratosphere Corp), Members Agreement (Ebs Building LLC)
Member Nonrecourse Debt Minimum Gain. In the event that there is a net decrease in Member Nonrecourse Debt Minimum Gain for a taxable year of the Company, then after taking into account allocations pursuant to paragraph (a) immediately preceding, but before any other allocations are made for such taxable year, each Member with a share of Member Nonrecourse Debt Minimum Gain at the beginning of such year shall be allocated items of Book income and gain for such year (and, if necessary, for subsequent years) to the extent required by Treas. Reg. §§ 1.704-2(i)(4).
Appears in 1 contract
Member Nonrecourse Debt Minimum Gain. In the event that there is a net decrease in Member Nonrecourse Debt Minimum Gain for a taxable year of the Joint Venture Company, then after taking into account allocations pursuant to paragraph (a) immediately preceding, but before any other allocations are made for such taxable year, each Member with a share of Member Nonrecourse Debt Minimum Gain at the beginning of such year shall be allocated items of Book income and gain for such year (and, if necessary, for subsequent years) to the extent required provided by Treas. Reg. §§ 1.704-2(i)(4).
Appears in 1 contract
Samples: Limited Liability Partnership Agreement (Micron Technology Inc)