Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities” of the Company as used in Section 1.752-3(a)(3) of the Treasury Regulations shall first be allocated among the Member pursuant to the “additional method” described in such section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to such liabilities will be allocated.
Appears in 2 contracts
Sources: Limited Liability Company Operating Agreement, Limited Liability Company Operating Agreement
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities” of the Company as used in Section 1.752-3(a)(3) of the Treasury Regulations shall will first be allocated among the Member pursuant to the “additional method” described in such that section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to such those liabilities will be allocated.allocated.
Appears in 2 contracts
Sources: Operating Agreement, Company Agreement
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities” of the Company as used in Section Treasury Regulations § 1.752-3(a)(3) of the Treasury Regulations shall first be allocated among the Member Members pursuant to the “additional method” described in such section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to such liabilities will be allocated.Members’ respective Percentages.
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Kennedy-Wilson Properties (IL)), Limited Liability Company Agreement (Harbin Electric, Inc)
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities” of the Company as used in Section 1.752-3(a)(3) of the Treasury Regulations shall first be allocated among the Member pursuant to the “additional method” described in such section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to such liabilities will be allocated.allocated.
Appears in 1 contract
Allocation of Excess Nonrecourse Liabilities. “Excess nonrecourse liabilities” of the Company as used in Section Treasury Regulations § 1.752-3(a)(3) of the Treasury Regulations shall first be allocated among the Member Members pursuant to the “additional method” described in such section and then in accordance with the manner in which the Manager expects the nonrecourse deductions allocable to such liabilities will be allocated.Members’ respective Percentages.
Appears in 1 contract
Sources: Operating Agreement