Pursuant to Treas. Reg. § 1.704-2(i)(1), deductions attributable to “partner nonrecourse liability” shall be allocated to the Member that bears the economic risk of loss for such liability (or is treated as bearing such risk).
Appears in 8 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Trilogy Metals Inc.), Asset Purchase Agreement (Kinross Gold Corp)
Pursuant to Treas. Reg. § 1.704-2(i)(1), deductions attributable to “"partner nonrecourse liability” " shall be allocated to the Member that bears the economic risk of loss for such liability (or is treated as bearing such risk). This Paragraph 4(b) shall apply before the application of Paragraph 4(a).
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Polymet Mining Corp), Combination Agreement (Polymet Mining Corp)
Pursuant to Treas. Reg. § Section 1.704-2(i)(1), deductions attributable to “"partner nonrecourse liability” " shall be allocated to the Member that bears or is treated as bearing the economic risk of loss for such liability (or is treated as bearing such risk)liability.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement, Limited Liability Company Operating Agreement (Uranium Energy Corp)
Pursuant to Treas. RegRegs. § 1.704-2(i)(1), deductions attributable to “partner nonrecourse liability” shall be allocated to the Member that bears the economic risk of loss for such liability (or is treated as bearing such risk).
Appears in 1 contract
Samples: Limited Liability Company Agreement (General Moly, Inc)
Pursuant to Treas. Reg. § 1.704-2(i)(1), deductions attributable to “"partner nonrecourse liability” " shall be allocated to the Member that bears the economic risk of loss for such liability (or is treated as bearing such risk).
Appears in 1 contract
Pursuant to Treas. Reg. § §1.704-2(i)(1), deductions attributable to “partner nonrecourse liability” shall be allocated to the Member that bears the economic risk of loss for such liability (or is treated as bearing such risk).
Appears in 1 contract
Samples: Exploration, Development & Mine Operating Agreement (Crosshair Exploration & Mining Corp)
Pursuant to Treas. Reg. § 1.704-2(i)(1), deductions attributable to “partner nonrecourse liability” "PARTNER NONRECOURSE LIABILITY" shall be allocated to the Member that bears the economic risk of loss for such liability (or is treated as bearing such risk).
Appears in 1 contract
Samples: Members' Agreement (Battle Mountain Gold Exploration Corp.)
