Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j).
Appears in 31 contracts
Samples: Company Agreement (BlueRiver Acquisition Corp.), Limited Liability Company Agreement (Rani Therapeutics Holdings, Inc.), Operating Agreement (Enfusion, Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss associated with respect to the liability to which such Member Nonrecourse Deductions are attributable deductions, in accordance with Treasury Regulations Section 1.704-2(j2(i).
Appears in 15 contracts
Samples: Operating Agreement, Operating Agreement, Limited Liability Company Agreement
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 13 contracts
Samples: Limited Liability Company Agreement (Calyxt, Inc.), Business Combination Agreement (Spree Acquisition Corp. 1 LTD), Limited Liability Company Agreement (Azz Inc)
Member Nonrecourse Deductions. Notwithstanding anything to the contrary in this Agreement, any Member Nonrecourse Deductions for any taxable year or other period shall for which allocations are made will be allocated to the Member who bears the economic risk of loss with respect to the liability Member nonrecourse debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i).
Appears in 9 contracts
Samples: Joint Venture Formation and Limited Liability Company Investment Agreement (American Well Corp), Company Agreement (Environmental Procedures Inc), Company Agreement (Golfsmith International Holdings Inc)
Member Nonrecourse Deductions. Notwithstanding anything to the contrary in this Agreement, any Member Nonrecourse Deductions for any taxable year or other period shall for which allocations are made will be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i).
Appears in 8 contracts
Samples: Limited Liability Company Agreement (Hilton Grand Vacations Inc.), Limited Liability Company Agreement (Grubb & Ellis Healthcare REIT II, Inc.), Limited Liability Company Agreement (Glimcher Realty Trust)
Member Nonrecourse Deductions. Notwithstanding anything to the contrary in this Agreement, any Member Nonrecourse Deductions for any taxable year or other period shall for which allocations are made will be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i).
Appears in 7 contracts
Samples: Limited Liability Company Agreement (QTS Realty Trust, Inc.), Limited Liability Company Agreement (Greenbrier Companies Inc), Limited Liability Company Agreement (Greenbrier Companies Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Taxable Year shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j1.704‑2(i)(1).
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Clearway Energy LLC), Limited Liability Company Agreement (Clearway Energy, Inc.), Limited Liability Company Agreement (NRG Yield, Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation section 1.704-2(j).
Appears in 5 contracts
Samples: Investment Agreement (Krupp Family Limited Partnership 94), Investment Agreement (Krf3 Acquisition Co LLC), Investment Agreement (Krupp Family Limited Partnership 94)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation Sections 1.704-2(j2(i) and (j).
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Pattern Energy Group Inc.), Purchase and Sale Agreement (Pattern Energy Group Inc.), Limited Liability Company Agreement (Pattern Energy Group Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i).
Appears in 4 contracts
Samples: Operating Agreement (Convergence, LLC), Operating Agreement (Convergence, LLC), Limited Liability Company Operating Agreement (Edgen Group Inc.)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Taxable Year shall be allocated to the Member who bears or Members that bear the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with the manner required by Treasury Regulations Regulation Section 1.704-2(j2(i).
Appears in 4 contracts
Samples: Limited Liability Company Operating Agreement (Forte Investment Fund, LLC), Limited Liability Company Operating Agreement (Concreit Series LLC), Limited Liability Company Operating Agreement (Concreit Series LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period year shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (American Retirement Corp), Limited Liability Company Agreement (American Retirement Corp), Limited Liability Company Agreement (American Retirement Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period year shall be allocated to the Member who bears Member(s) bearing the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (DiCE MOLECULES HOLDINGS, LLC), Limited Liability Company Agreement (DiCE MOLECULES HOLDINGS, LLC), Operating Agreement (Evolent Health, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Taxable Year shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j1.704 2(i)(1).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Clearway Energy, Inc.), Limited Liability Company Agreement (Clearway Energy LLC), Limited Liability Company Agreement (Clearway Energy, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Taxable Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Regulation Section 1.704-2(j2(i) (1).
Appears in 3 contracts
Samples: Operating Agreement (Chiles Magellan LLC), Operating Agreement (Seacor Smit Inc), Operating Agreement (Seacor Smit Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Treas. Reg. § 1.704-2(j2(i).
Appears in 2 contracts
Samples: Operating Agreement, Operating Agreement (Elk Horn Coal Co LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Regulation Section 1.704-2(j2(i).
Appears in 2 contracts
Samples: Operating Agreement (Bequest Bonds I Inc), Operating Agreement (Bequest Bonds I Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable tax period shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Regulation Section 1.704-2(j2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (GDT TEK, Inc.), Limited Liability Company Agreement (Composite Technology Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Taxable Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation §1.704-2(j2(i)(1).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Pc Tel Inc), Limited Liability Company Agreement (Pc Tel Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions Deduction for any taxable year or other period shall be specially allocated to the Member Interest Holder who bears the economic risk of loss with respect to the liability to which such the Member Nonrecourse Deductions are Deduction is attributable in accordance with Treasury Regulations Regulation Section 1.704-2(j2(i).
Appears in 2 contracts
Samples: Operating Agreement, Limited Liability Company Agreement (Voicestream Wireless Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Taxable Year shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Liability with respect to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j)2(b)(4) of the Regulations.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Premier Finance Biloxi Corp), Operating Agreement (Premier Finance Biloxi Corp)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable Taxable Year or other period shall will be specially allocated to the Member who bears the economic risk of loss with respect to the liability “partner nonrecourse debt” (as that term is defined in Regulations Section 1.704-2(b)(4)) to which such the Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 2 contracts
Samples: Operating Agreement (New Clearwire CORP), Operating Agreement (Clearwire Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable year or other period shall will be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with principles under Treasury Regulations Regulation Section 1.704-2(j2(i).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Mid America Apartment Communities Inc), Limited Liability Company Agreement (Nineteen Eighty-Nine, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable year or other period shall will be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with principles under Treasury Regulations Section 1.704-2(j2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Cinemark Holdings, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period tax year shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j)2(i)(1) of the Treasury Regulations.
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period Taxable Period shall be allocated to in accordance with Treasury Regulations Section 1.704-(2)(i)(1) among Capital Accounts of Members bearing the Member who bears the economic risk Economic Risk of loss Loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j)attributable.
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period year shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704l.704-2(j)2(i)(l) of the Regulations.
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable Taxable Year or other period shall be allocated to the Member Holder who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Sections 1.704-2(j2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Treas. Reg. Section 1.704-2(j2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable Taxable Year or other period shall will be specially allocated to w the Member who bears the economic risk of loss with respect to the liability “partner nonrecourse debt” (as that term is defined in Regulations Section 1.704-2(b)(4)) to which such the Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 1 contract
Samples: Operating Agreement (Wcof, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable Taxable Year or other relevant period shall be specially allocated to the Member who that bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j)2.
Appears in 1 contract
Samples: Joint Venture and Limited Liability Company Agreement (Griffin Realty Trust, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable Taxable Year or other period shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Sections 1.704-2(j2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Legion Capital Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Taxable Period shall be specially allocated to the Member who that bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Charter Communications, Inc. /Mo/)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period year shall be allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i)(l).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Taxable Year shall be allocated to the Member who bears Member(s) bearing the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2 (i)(1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable Taxable Year or other period shall be allocated to the Member Holder who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Sections 1.704-2(j2(i)(1) and 1.704-2(i)(2).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Capital Growth Systems Inc /Fl/)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period year shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j1.704 2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period Tax Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j)2(i)(l) of the Treasury Regulations.
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any taxable period year shall be allocated to the Member who bears Member(s) bearing the economic risk of loss with respect to the liability Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i)(1).
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Consolidated Tomoka Land Co)
Member Nonrecourse Deductions. Member Nonrecourse Deductions for any taxable period shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j2(i).,
Appears in 1 contract
