Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities” of the Fund as used in Section 1.752-3(a)(3) of the Treasury Regulations will first be allocated among the Member pursuant to the “additional method” described in that section and then in accordance with the manner in which the Administrator expects the nonrecourse deductions allocable to those liabilities will be allocated.
Appears in 8 contracts
Sources: Subscription Agreement, Subscription Agreement, Subscription Agreement
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities” " of the Fund as used in Section 1.752-3(a)(3) of the Treasury Regulations will first be allocated among the Member pursuant to the “"additional method” " described in that section and then in accordance with the manner in which the Administrator Manager expects the nonrecourse deductions allocable to those liabilities will be allocated.
Appears in 5 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement