Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears the economic risk of loss for the Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § 1.704-2(i)(1). If more than one Member bears the economic risk of loss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 4 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement, Member Control Agreement (Dakota Plains Holdings, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears If one or more Members bear the economic risk of loss for (within the meaning of Section 1.752-2 of the Treasury Regulations) with respect to any Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § 1.704-2(i)(1). If more than one Debt, Member bears the economic risk of loss, such deduction Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which such Members share such Membership Interest the economic risk of lossloss for such Member Nonrecourse Debt.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Nco Portfolio Management Inc), Limited Liability Company Agreement (Nco Portfolio Management Inc), Limited Liability Company Agreement (Nco Portfolio Management Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears the economic risk Economic Risk of loss Loss for the Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § Treasury Regulations Section 1.704-2(i)(1). If more than one Member bears the economic risk Economic Risk of lossLoss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk Economic Risk of lossLoss.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Energysouth Inc), Limited Liability Company Agreement (Tefron LTD)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears If one or more Members bear the economic risk of loss for (within the meaning of Section 1.752-2 of the Treasury Regulations) with respect to any Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § 1.704-2(i)(1). If more than one Debt, Member bears the economic risk of loss, such deduction Nonrecourse Deductions attributable thereto shall be allocated between or among such Members in accordance with the ratios in which such Members share such the economic risk of lossloss for such Member Nonrecourse Debt.
Appears in 2 contracts
Samples: Operating Agreement (Kellstrom Industries Inc), Operating Agreement (Aviation Sales Co)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions Deduction shall be allocated to the Member that who bears the economic risk of loss for with respect to the Member Nonrecourse Debt loan to which such deductions relate as provided Member Nonrecourse Deductions are attributable in accordance with Treas. Reg. § Section 1.704-2(i)(12(i). If more than one Member bears the economic risk of loss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 2 contracts
Samples: Operating Agreement (Land O Lakes Inc), Limited Liability Company Agreement (Land O Lakes Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions attributable to a Member Nonrecourse Debt shall be allocated to the Member (or Members) that bears bear the economic risk of loss for the such Member Nonrecourse Debt to which such deductions relate as provided in accordance with Treas. Reg. § 1.704l.704-2(i)(12(i)(l). If more than one Member bears the economic risk of loss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (MorningStar Partners, L.P.), Limited Liability Company Agreement (MorningStar Partners, L.P.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be specially allocated to the Member that bears Members who bear the economic risk of loss for with respect to the Member Nonrecourse Debt to which such deductions relate as provided Member Nonrecourse Deductions are attributable. This section 5.2.6 shall be interpreted and applied in Treas. Reg. § a manner consistent with Treas Reg 1.704-2(i)(1). If more than one Member bears the economic risk of loss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 2 contracts
Samples: Operating Agreement, Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears the economic risk Economic Risk of loss Loss for the Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § Section 1.704-2(i)(1)) of the Treasury Regulations. If more than one Member bears the economic risk Economic Risk of lossLoss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 2 contracts
Samples: Operating Agreement (Healtheon Webmd Corp), Operating Agreement (Healtheon Webmd Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears the economic risk of loss for the Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § Regulations §1.704-2(i)(1). If more than one Member bears the economic risk of loss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Terra Secured Income Fund 5, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears the economic risk Economic Risk of loss Loss for the Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § Treasury Regulation Section 1.704-2(i)(1). If more than one Member bears the economic risk Economic Risk of lossLoss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk Economic Risk of lossLoss.
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Deductions. Any All Member Nonrecourse Deductions attributable to a Member Nonrecourse Debt, shall be allocated to among the Member that bears Manager or the economic risk Members bearing the Economic Risk of loss Loss for the Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § 1.704-2(i)(1). If debt; provided, however, if more than one Member bears the economic risk Economic Risk of lossLoss for such debt, the Member Nonrecourse Deductions attributable to such deduction debt shall be allocated between or to and among such Members Persons, pro rata, in accordance with the ratios in which such Members share such economic risk same proportions that their Economic Risk of lossLoss bears to one another.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Nexcore Healthcare Capital Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears Members who bear the economic risk of loss for with respect to the Member Nonrecourse Debt to which such deductions relate as provided Member Nonrecourse Deductions are attributable. This Section 4.2.5 shall be interpreted and applied in Treas. Reg. § a manner consistent with Treas Reg 1.704-2(i)(1). If more than one Member bears the economic risk of loss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 1 contract
Samples: Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated to the Member that bears the economic risk Economic Risk of loss Loss for the Member Nonrecourse Debt to which such deductions relate as provided in Treas. Reg. § Section 1.704-2(i)(1)2(i)(l) of the Treasury Regulations. If more than one Member bears the economic risk Economic Risk of lossLoss, such deduction shall be allocated between or among such Members in accordance with the ratios in which such Members share such economic risk of loss.
Appears in 1 contract