Minimum Gain Attributable to Member Nonrecourse Debt means the amount of minimum gain there is in connection with a Member Nonrecourse Debt, calculated in the manner described in Treasury Regulation Section 1.704-2(i)(3).
Minimum Gain Attributable to Member Nonrecourse Debt means the amount determined pursuant to the provisions of Treasury Regulations Section 1.704-2(i)(3).
Minimum Gain Attributable to Member Nonrecourse Debt. The amount of gain which would be recognized by the Company for federal income tax purposes if all Company property secured by Member Nonrecourse Debt were transferred to the creditor of such debt in satisfaction thereof (and for no other consideration) in a taxable transaction. The amount of such gain shall be determined and calculated in accordance with Treasury Regulation Section 1.704-2(f) (i) (4).
Examples of Minimum Gain Attributable to Member Nonrecourse Debt in a sentence
Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt 14 C.
For purposes of this section, the amount of each Member's share of Company Minimum Gain and each Member's share of Minimum Gain Attributable to Member Nonrecourse Debt (each as hereinafter defined) shall be treated as a limited dollar deficit make-up obligation in such amounts and accordingly shall, for purposes of the preceding sentence, be added to the limited dollar amount (if any) of the deficit balance in such Member's Adjusted Book Capital Account that such Member is required to restore.
Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt .
For purposes of determining Capital Accounts under this Section 4.4: (i) Capital Accounts shall be reduced by distributions with respect to such Fiscal Year, and (ii) a Member’s Capital Account shall be increased by such Member’s share of Minimum Gain and Minimum Gain Attributable to Member Nonrecourse Debt determined as of the end of such Fiscal Year.
Chargeback of Minimum Gain Attributable to Member Nonrecourse Debt.
More Definitions of Minimum Gain Attributable to Member Nonrecourse Debt
Minimum Gain Attributable to Member Nonrecourse Debt means “partner nonrecourse debt minimum gain” as determined in accordance with Regulations Section 1.704-2(i)(3).
Minimum Gain Attributable to Member Nonrecourse Debt means that amount determined in accordance with the principles of Treasury Regulation Section 1.704-2(i)(3).
Minimum Gain Attributable to Member Nonrecourse Debt means "partner nonrecourse debt minimum gain" as determined in accordance with Regulations Section 1.704-2(i)(3).
Minimum Gain Attributable to Member Nonrecourse Debt that amount with respect to each Member Nonrecourse Debt that is equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with the principles of Treasury Regulation Section 1.704-2(i)(3).
Minimum Gain Attributable to Member Nonrecourse Debt shall have the same meaning as "partner nonrecourse debt minimum gain" as determined in accordance with section 1.704-2(i)(2) of the Regulations.
Minimum Gain Attributable to Member Nonrecourse Debt means the amount determined pursuant to the provisions of Treasury Regulations Section 1.704-2(i)(3). K. "Nonrecourse Deductions" has the meaning set forth in Treasury Regulations Section 1.704-2(b)(1). L. "Nonrecourse Liability" means those liabilities defined as such in Treasury Regulations Section 1.704-2(b)(3). M. "Membership Interest" means, with respect to a member, the member's Interest (as defined in Article I, Section 2 of this Agreement), the member's rights to distributions (liquidating or otherwise), the member's tax allocations (if any), and the member's information and rights to vote, consent, or approve. N. "Profit" or "Loss" means, for any Fiscal Year, an amount equal to the Company's taxable income or loss for such Fiscal Year, determined in accordance with the Code Section 703(a) (for this purpose, all items of income, gain, loss, or deduction required to be stated separately pursuant to Code Section 703(a)(1) shall be included in taxable income or loss), with the following adjustments: Any income of the Company that is exempt from federal income tax and not otherwise taken into account in computing Profits or Losses pursuant to this definition of "Profits" and "Losses" shall be added to such taxable income or loss; In the event the Carrying Value of any Company property is adjusted pursuant to the definition of Carrying Value, the amount of such adjustment shall be taken into account as gain or loss from the disposition of such asset for purposes of computing Profits or Losses; Any expenditures of the Company described in Code Section 705(a)(2)(B) or treated as Code Section 705(a)(2)(B) expenditures pursuant to Treasury Regulations Section 1.704-1(b)(2)(iv)(i), and not otherwise taken into account in computing Profits or Losses pursuant to this definition of "Profits" and "Losses" shall be subtracted from such taxable income or Loss; Gain or loss resulting from any disposition of Company property with respect to which gain or loss is recognized for federal income tax purposes shall be computed by reference to the Carrying Value of the Company property disposed of, notwithstanding that the adjusted tax basis of such Company property differs from its Carry Value; In lieu of depreciation, amortization and other cost recovery deductions taken into account in computing such taxable income or loss, there shall be taken into account Depreciation for such Allocation Year, computed in accordance with the definition of "Depreciation"; To the exten...
Minimum Gain Attributable to Member Nonrecourse Debt means the