Unitholder Nonrecourse Deductions. Any Unitholder Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Unitholder who bears the economic risk of loss with respect to the Unitholder Nonrecourse Debt to which such Unitholder Nonrecourse Deductions are attributable in accordance with Regulations, Section 1.704-2(i)(1).
Appears in 7 contracts
Samples: Limited Liability Company Agreement (U. S. Premium Beef, LLC), Limited Liability Company Agreement (U. S. Premium Beef, LLC), Limited Liability Company Agreement (Illini Bio-Energy, LLC)
Unitholder Nonrecourse Deductions. Any Unitholder Nonrecourse Deductions for any Fiscal Year shall be specially allocated to the Unitholder who bears the economic risk of loss with respect to the Unitholder Nonrecourse Debt to which such Unitholder Nonrecourse Deductions are attributable in accordance with Regulations, Treasury Regulations Section 1.704-2(i)(1)2.
Appears in 3 contracts
Samples: Agreement and Declaration of Trust (Cushing MLP Infrastructure Fund II), Agreement and Declaration of Trust (Cushing MLP Infrastructure Master Fund), Agreement and Declaration of Trust (Cushing MLP Infrastructure Fund)
Unitholder Nonrecourse Deductions. Any Unitholder Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Unitholder who bears the economic risk of loss with respect to the Unitholder Nonrecourse Debt to which such Unitholder Nonrecourse Deductions are attributable in accordance with Regulations, U.S. Treasury Regulations Section 1.704-2(i)(1).2(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement
Unitholder Nonrecourse Deductions. Any Unitholder Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Unitholder who bears the economic risk of loss with respect to the Unitholder Nonrecourse Debt to which such Unitholder Nonrecourse Deductions are attributable in accordance with Regulations, U.S. Treasury Regulations Section 1.704-2(i)(12(i).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Macquarie Infrastructure Holdings, LLC)