Nonrecourse Deductions and Member Nonrecourse Deductions. Any Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holders in accordance with their respective Percentage Interests. Any Member Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Holder(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable, in accordance with Regulations Section 1.704-2(i).
Nonrecourse Deductions and Member Nonrecourse Deductions. Any Nonrecourse Deductions for any fiscal year shall be specially allocated to the Members in shall be allocated in the same manner in which such items would have been allocated pursuant to Section 6.2. Any Member Nonrecourse Deductions for any fiscal year shall be specially allocated to the Member(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable, in accordance with Regulations Sections 1.704-2(b)(4) and 1.704-2(i).
Nonrecourse Deductions and Member Nonrecourse Deductions. Any Nonrecourse Deductions for any Company Year shall be specially allocated (x) first, among the Holders of Company Common Units and OPEUs in accordance with their respective Percentage Interests with respect to Company Common Units and OPEUs and (y) thereafter, among the Holders of other classes of Company Units as determined by the Managing Member. Any Member Nonrecourse Deductions for any Company Year shall be specially allocated to the Holder(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable, in accordance with Regulations Section 1.704-2(i).
Nonrecourse Deductions and Member Nonrecourse Deductions. Nonrecourse Deductions as defined in Regulations Section 1.704-2(c) shall be allocated according to the Membership Interest of each Member. Notwithstanding any provision hereof to the contrary, any item of Company loss, deduction, or expenditure described in Code Section 705(a)(2)(B) for any Fiscal Year (or any portion of any such item) that is required to be allocated to the Members under Regulations Section 1.704-2(i)(1) shall be allocated to the Members for such Fiscal Year in the manner so required by such Regulation.
Nonrecourse Deductions and Member Nonrecourse Deductions. Any Nonrecourse Deductions for any Company Year shall be specially allocated to the Holders of Membership Units in accordance with their Membership Units. Any Member Nonrecourse Deductions for any Company Year shall be specially allocated to the Holder(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable, in accordance with Regulations Section 1.704-2(i).
Nonrecourse Deductions and Member Nonrecourse Deductions. The Nonrecourse Deductions for each Fiscal Year shall be allocated to the Members pro rata in proportion to their Percentage Interests. The Member Nonrecourse Deductions for each Fiscal Year shall be allocated to the Member that bears the economic risk of loss (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable.
Nonrecourse Deductions and Member Nonrecourse Deductions. Nonrecourse Deductions as defined in Section l.704-2(b)(l) and Section 1.704-2(c) of the Regulations shall be allocated to the Members in accordance with and on the same basis as the allocation of Net Losses. Notwithstanding any provision hereof to the contrary, "partner nonrecourse deductions" as defined in the Regulations Section 1.704-2(i)(1) and Section 1.704-2(i)(2) for any Fiscal Year or other period shall be specially allocated to the Members who bear the economic risk of loss for the "partner nonrecourse debt" to which such "partner nonrecourse deductions" are attributable, as provided in Regulations Section l.704-2(i)(l).
Nonrecourse Deductions and Member Nonrecourse Deductions. The Nonrecourse Deductions for each taxable year of the Company shall be allocated to the Members in proportion to their Common Percentage Interests. The Member Nonrecourse Deductions shall be allocated each year to the Member that bears the economic risk of loss (within the meaning of Treasury Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable.
Nonrecourse Deductions and Member Nonrecourse Deductions. Nonrecourse Deductions for any Allocation Year shall be allocated pursuant to the Membership Interests as designated in Exhibit B as may be amended.
Nonrecourse Deductions and Member Nonrecourse Deductions. Notwithstanding anything to the contrary contained in this Article II hereof, (i) Nonrecourse Deductions (as defined in Section 2.4C) shall be allocated to the Members in proportion to their respective Company Percentages in effect for the period with respect to which such allocation is being made and (ii) any and all items of loss and deduction and any and all expenditures described in Section 705(a)(2)(B) of the Code (or treated as expenditures so described pursuant to Section 1.704-1(b)(2)(iv)(i) of the Income Tax Regulations) (collectively, "Member Nonrecourse Deductions") that are (in accordance with the principles set forth in Section 1.704-2(i)(2) of the Income Tax Regulations) attributable to Member Nonrecourse Debt shall be allocated to the Member that bears the Economic Risk of Loss for such Member Nonrecourse Debt. If more than one Member bears such Economic Risk of Loss, such Member Nonrecourse Deductions shall be allocated between or among such Members in accordance with the ratios in which they share such Economic Risk of Loss. If more than one Member bears such Economic Risk of Loss for different portions of a Member Nonrecourse Debt, each such portion shall be treated as a separate Member Nonrecourse Debt.
