Venturer Nonrecourse Debt definition

Venturer Nonrecourse Debt shall have the meaning for partner nonrecourse debt set forth in Treasury Regulations Section 1.704-2(b)(4), and the termVenturer Nonrecourse Debt Minimum Gain” shall have the meaning for partner nonrecourse debt minimum gain set forth in Treasury Regulations Section 1.704-2(i)(2). This Section 5.4(c) is intended to satisfy the requirements of Treasury Regulations Section 1.704-2(i)(4) (including the partner nonrecourse debt minimum gain chargeback requirement) and shall be interpreted and applied in a manner consistent therewith.
Venturer Nonrecourse Debt is defined in Section 3.5.6 hereof.
Venturer Nonrecourse Debt has the meaning ascribed to the term "Partner Nonrecourse Debt" set forth in Regulations Section 1.704-2(b)(4).

Examples of Venturer Nonrecourse Debt in a sentence

  • Each of the Lenders hereby irrevocably appoints Xxxxx Fargo to act on its behalf as the Administrative Agent hereunder and under the other Loan Documents and authorizes the Administrative Agent to take such actions on its behalf and to exercise such powers as are delegated to the Administrative Agent by the terms hereof or thereof, together with such actions and powers as are reasonably incidental thereto.

  • All Losses shall be allocated to the -------------------- Venturers (other than Paddlewheels and any Affiliate thereof) in proportion to such Venturers' Relative Ownership Ratios; provided, however, that any Losses (or portion thereof) attributable to a loan made or guaranteed by a Venturer, or Venturer nonrecourse debt within the meaning of Regulation Section 1.704-2(b)(4) ("Venturer Nonrecourse Debt"), shall be allocated to such Venturer in accordance with such Regulation.

  • Throughout the term of the Venture, the nonrecourse debt of the Venture (other than Venturer Nonrecourse Debt) shall be allocated for tax purposes among the Venturers in accordance with their then respective Residual Percentages.

  • Notwithstanding any other provision of this Agreement, to the extent required by Treasury Regulations Section 1.704-2(I), any items of income, gain, loss or deduction of the Venture that are attributable to a nonrecourse debt of the Venture that constitutes Venturer Nonrecourse Debt (including chargebacks of Venturer Nonrecourse Debt Minimum Gain) shall be allocated in accordance with the provisions of Treasury Regulations Section 1.704-2(i).

  • For purposes of this Agreement, the term "Venturer Nonrecourse Debt" shall have the meaning for partner nonrecourse debt set forth in Treasury Regulations Section 1.704-2(b)(4), and the term "Venturer Nonrecourse Debt Minimum Gain" shall have the meaning for partner nonrecourse debt minimum gain set forth in Treasury Regulations Section 1.704-2(I)(2).

  • All Losses shall be allocated to the -------------------- Venturers (other than Paddlewheels and any Affiliate thereof) in proportion to such Venturers' Relative Ownership Ratios; provided, however, that any Losses (or portion thereof) attributable to a loan made or guaranteed by a Venturer, or Venturer nonrecourse debt within the meaning of Regulation Section 1.704-2(b)(4) ("Venturer Nonrecourse Debt"), shall be allocated to ------------------------- such Venturer in accordance with such Regulation.


More Definitions of Venturer Nonrecourse Debt

Venturer Nonrecourse Debt shall have the meaning set forth in Treasury Regulations (S) 1.704-2(b) (4) for "partner nonrecourse debt."
Venturer Nonrecourse Debt shall have the same meaning as "partner nonrecourse debt" set forth in Treas. Reg. Section 1.704-2(b)(4). The amount of Venturer nonrecourse deductions with respect to a Venturer nonrecourse debt for a fiscal year equals the excess, if any, of the net increase, if any, in the amount of Venture minimum gain attributable to such Venturer nonrecourse debt during such fiscal year over the aggregate amount of the proceeds of the liability distributed during that fiscal year to the Venturer that bears the economic risk of loss for such Venturer nonrecourse debt. The inclusion of references in this Section 5.2 to specific Regulation Sections is not intended to imply that other Regulations are not to apply, the Venturers' intent being that all provisions of Regulation Section 1.704 are to apply to the allocation of profits and losses under this Agreement.
Venturer Nonrecourse Debt shall have the meaning as defined in Section ------------------------- 5.2(b) below. "Vessel" - shall mean a riverboat gaming vessel having approximately 30,000 ------ square feet of net gaming space or such other amount of net gaming space as may be permitted under applicable Louisiana law, which riverboat gaming vessel shall be located at the Venture Site in Shreveport, Louisiana.

Related to Venturer Nonrecourse Debt

  • Member Nonrecourse Debt has the meaning of “partner nonrecourse debt” set forth in Treasury Regulations Section 1.704-2(b)(4).

  • Partner Nonrecourse Debt has the meaning set forth in Treasury Regulation Section 1.704-2(b)(4).

  • Nonrecourse Debt means any Company liability to the extent that no Member or related Person bears the economic risk of loss for such liability under Section 1.752-2 of the Treasury Regulations.

  • Member Nonrecourse Debt Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Partner Nonrecourse Debt Minimum Gain has the meaning set forth in Treasury Regulation Section 1.704-2(i)(2).

  • Member Nonrecourse Deduction means “partner nonrecourse deduction” as defined in Treasury Regulations Section 1.704-2(i), substituting the term “Member” for the term “partner” as the context requires.

  • Member Nonrecourse Deductions has the meaning of “partner nonrecourse deductions” set forth in Treasury Regulations Sections 1.704-2(i)(1) and 1.704-2(i)(2).

  • Partner Nonrecourse Deductions means any and all items of loss, deduction or expenditure (including any expenditure described in Section 705(a)(2)(B) of the Code) that, in accordance with the principles of Treasury Regulation Section 1.704-2(i), are attributable to a Partner Nonrecourse Debt.

  • Recourse Debt means Indebtedness that is not Non-Recourse Indebtedness.

  • Nonrecourse Deduction shall have the meaning given such term in Regulations Section 1.704-2(b)(1).

  • Nonrecourse Deductions has the meaning set forth in Section 1.704-2(b)(1) of the Regulations.

  • Nonrecourse Liability has the meaning set forth in Regulations Section 1.752-1(a)(2).

  • Nonrecourse Built-in Gain means with respect to any Contributed Properties or Adjusted Properties that are subject to a mortgage or pledge securing a Nonrecourse Liability, the amount of any taxable gain that would be allocated to the Partners pursuant to Section 6.2(b) if such properties were disposed of in a taxable transaction in full satisfaction of such liabilities and for no other consideration.

  • Nonrecourse Liabilities has the meaning set forth in Section 1.704-2(b)(3) of the Regulations.

  • Nonrecourse Indebtedness means, with respect to a Person, Indebtedness for borrowed money in respect of which recourse for payment (except for customary exceptions for fraud, misapplication of funds, environmental indemnities, voluntary bankruptcy, collusive involuntary bankruptcy and other similar customary exceptions to nonrecourse liability) is contractually limited to specific assets of such Person encumbered by a Lien securing such Indebtedness.

  • Non-Recourse Debt means Indebtedness:

  • Nonrecourse Obligation means indebtedness or other obligations substantially related to (i) the acquisition of assets not previously owned by the Company or any Restricted Subsidiary or (ii) the financing of a project involving the development or expansion of properties of the Company or any Restricted Subsidiary, as to which the obligee with respect to such indebtedness or obligation has no recourse to the Company or any Restricted Subsidiary or any assets of the Company or any Restricted Subsidiary other than the assets which were acquired with the proceeds of such transaction or the project financed with the proceeds of such transaction (and the proceeds thereof).

  • Member Minimum Gain means an amount, with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Partner Minimum Gain means an amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3).

  • Minimum Gain means “partnership minimum gain” determined pursuant to Treasury Regulation Section 1.704-2(d).

  • Partnership Year means the fiscal year of the Partnership, which shall be the calendar year.

  • Partnership Minimum Gain has the meaning set forth in Regulations Section 1.704-2(b)(2), and the amount of Partnership Minimum Gain, as well as any net increase or decrease in Partnership Minimum Gain, for a Partnership Year shall be determined in accordance with the rules of Regulations Section 1.704-2(d).

  • Company Minimum Gain has the meaning given the term “partnership minimum gain” in Sections 1.704-2(b)(2) and 1.704-2(d) of the Regulations.

  • Net Loss means, for each fiscal year or other applicable period, an amount equal to the Partnership’s taxable income or loss for such year or period as determined for federal income tax purposes by the General Partner, determined in accordance with Section 703(a) of the Code (for this purpose, all items of income, gain, loss or deduction required to be stated separately pursuant to Section 703(a) of the Code shall be included in taxable income or loss), adjusted as follows:

  • Book Capital Account means, for any Holder at any time, the Book Capital Account of the Holder for such day, determined in accordance with Section 8.1 hereof.

  • Consolidated Net Loss for any fiscal period, means the amount which, in conformity with GAAP, would be set forth opposite the caption "net income" (or any like caption), as the case may be, on a consolidated statement of earnings of the Borrower and its Subsidiaries, if any, for such fiscal period.