Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Member Nonrecourse Deductions shall be specially allocated to the Members who bear the economic risk of loss with respect to the Member Nonrecourse Debt to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 7 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement (Paradyme Fund a Ii, LLC)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Member Nonrecourse Deductions shall be specially allocated to among the Members who bear the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with Treasury the requirements of Regulations Section 1.704-2(i2(b)(4) and (i)(1).
Appears in 7 contracts
Sources: Limited Liability Company Agreement (Vince Holding Corp.), Membership Interest Purchase Agreement (XCel Brands, Inc.), Operating Agreement (Xspand Products Lab, Inc.)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Member Nonrecourse Deductions shall will be specially allocated to the Members who that bear the economic risk of loss with respect to (within the meaning of Treasury Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)attributable.
Appears in 6 contracts
Sources: Limited Liability Company Agreement (Crestwood Midstream Partners LP), Limited Liability Company Agreement, Limited Liability Company Agreement (Crestwood Midstream Partners LP)
Member Nonrecourse Deductions. Notwithstanding any other provision of anything to the contrary in this Agreement, any Member Nonrecourse Deductions shall for any Fiscal Year or other period for which allocations are made will be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Regulation Section 1.704-2(i).
Appears in 5 contracts
Sources: Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.), Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.), Operating Agreement (Jack Miller Family Limited Partnership 1)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions (as defined under Regulations Section 1.704-2(i)(2)) shall be specially allocated pursuant to Regulations Section 1.704-2(i)(1) to the Members Member who bear bears the economic risk of loss with respect to the “Member Nonrecourse Debt Debt” to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i)it is attributable.
Appears in 4 contracts
Sources: Operating Agreement (Diamond Resorts Corp), Operating Agreement (Diamond Resorts Corp), Operating Agreement (155 East Tropicana, LLC)
Member Nonrecourse Deductions. Notwithstanding any other provision In accordance with the provisions of this AgreementTreasury Regulation Section 1.704-2(i), any each item of Member Nonrecourse Deductions Deduction shall be specially allocated to among the Members who bear in proportion to the economic risk of loss that the Members bear with respect to the Member Nonrecourse Debt nonrecourse liability of the Company to which such items are attributable in accordance with Treasury Regulations Section 1.704-2(i)item of Member Nonrecourse Deduction is attributable.
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Maxygen Inc), Limited Liability Company Agreement (Maxygen Inc), Operating Agreement (Liveworld Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation § 1.704-2(i).
Appears in 4 contracts
Sources: Operating Agreement, Operating Agreement, Operating Agreement (West Corp)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any All Member Nonrecourse Deductions shall be specially allocated attributable to the Members who bear the economic risk of loss with respect to the Member Nonrecourse Debt to which shall be allocated among the Members bearing the Economic Risk of Loss for such items are attributable in accordance debt consistent with Treasury Regulations Section 1.704-2(i)2(i)(1) of the Regulations.
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Skechers Usa Inc), Limited Liability Company Agreement (Skechers Usa Inc), Limited Liability Company Agreement (Skechers Usa Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members who bear Member that bears the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt member nonrecourse debt to which such items are attributable deductions relate as provided in accordance with Treasury Regulations Regulation Section 1.704-2(i1.7042(i)(1).
Appears in 3 contracts
Sources: Limited Liability Company Agreement (KPMG Consulting Inc), Limited Liability Company Agreement (KPMG Consulting Inc), Limited Liability Company Agreement (KPMG Consulting Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk Economic Risk of loss Loss with respect to the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i2(i)(1). This provision is to be interpreted in a manner consistent with the requirements of Section 1.704-2(b)(4) and (i)(1) of the Treasury Regulations.
Appears in 2 contracts
Sources: Joint Venture Operating Agreement (Grown Rogue International Inc.), Limited Liability Company Operating Agreement
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall will be specially allocated to the Members who bear Member that bears the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt member nonrecourse debt to which such items are attributable deductions relate as provided in accordance with Treasury Regulations Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Simon Worldwide Inc), Limited Liability Company Agreement (Simon Worldwide Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of anything to the contrary in this Agreement, any Member Nonrecourse Deductions for any taxable year or other period for which allocations are made shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Cb Richard Ellis Realty Trust), Limited Liability Company Agreement (Cb Richard Ellis Realty Trust)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items are attributable Member Nonrecourse Deductions relate in accordance with Treasury Regulations Section 1.704-2(i).; and
Appears in 2 contracts
Sources: Master Purchase and Sale Agreement (Plum Creek Timber Co Inc), Master Purchase and Sale Agreement (MEADWESTVACO Corp)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss (within the meaning of Treasury Regulations Section 1.752-2) with respect to the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with and as required by Treasury Regulations Regulation Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (DJSP Enterprises, Inc.), Limited Liability Company Agreement (Chardan 2008 China Acquisition Corp.)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall will be specially allocated to the Members who bear Member that takes the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt to which such items are attributable deductions relate as provided in accordance with Treasury Regulations Regulation Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Sources: Operating Agreement (Playboy Enterprises Inc), Operating Agreement (Claxson Interactive Group Inc)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreementhereof to the contrary, any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i2(i)(1).
Appears in 2 contracts
Sources: Operating Agreement (Moody National REIT I, Inc.), Operating Agreement (Moody National REIT I, Inc.)
Member Nonrecourse Deductions. Notwithstanding any other provision of this AgreementAgreement to the contrary, any Member Nonrecourse Deductions shall will be specially allocated to the Members Member who bear (in his, her or its capacity, directly or indirectly, as lender, guarantor, or otherwise) bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items partner nonrecourse deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Gatx Corp), Limited Liability Company Agreement (Gatx Corp)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members who bear Member that takes the economic risk Economic Risk of loss with respect to Loss for the Member Nonrecourse Debt to which such items are attributable deductions relate as provided in accordance with Treasury Regulations Regulation Section 1.704-2(i2(i)(1).
Appears in 1 contract
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members who bear Member that bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704Regulation (S)1.704-2(i).
Appears in 1 contract
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704l.704-2(i).
Appears in 1 contract
Sources: Operating Agreement (Bespoke Capital Acquisition Corp)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions Deduction shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704ss.1.704-2(i2(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Cenex Harvest States Cooperatives)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Any Member Nonrecourse Deductions Deduction shall be specially allocated to the Members Member who bear bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such items Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section Regulation § 1.704-2(i).
Appears in 1 contract