Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 59 contracts
Sources: Limited Liability Company Agreement (At&t Inc.), Limited Liability Company Agreement (At&t Inc.), Limited Liability Company Agreement (At&t Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 19 contracts
Sources: Limited Liability Company Agreement (Mid-Con Energy Partners, LP), Merger Agreement (Williams Companies Inc), Merger Agreement (Energy Transfer Equity, L.P.)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)attributable.
Appears in 14 contracts
Sources: Exchange and Redemption Agreement, Exchange and Redemption Agreement, Implementation Agreement (Arch Coal Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 13 contracts
Sources: Limited Liability Company Agreement (Oasis Petroleum Inc.), Limited Liability Company Agreement (RiverBanc Multifamily Investors, Inc.), Contribution Agreement (RiverBanc Multifamily Investors, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year taxable year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 7 contracts
Sources: Limited Liability Company Agreement (Penske Automotive Group, Inc.), Limited Liability Company Agreement (Penske Automotive Group, Inc.), Limited Liability Company Agreement (Penske Automotive Group, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Treasury Regulation Section 1.704-2(i)(1).
Appears in 7 contracts
Sources: Limited Liability Company Agreement (Phillips Edison Grocery Center Reit Ii, Inc.), Operating Agreement (Key Plastics Inc), Operating Agreement (Key Plastics Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(12(i).
Appears in 7 contracts
Sources: Operating Agreement, Operating Agreement (Air T Inc), Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt or other liability to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i) and Regulations Section 1.704-1(b).
Appears in 6 contracts
Sources: Limited Liability Company Operating Agreement (Pinnacle Entertainment Inc), Limited Liability Company Agreement (Charter Communications Inc /Mo/), Limited Liability Company Agreement (Charter Communications Inc /Mo/)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations § 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)attributable.
Appears in 6 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement (CAESARS ENTERTAINMENT Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Common Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Oasis Midstream Partners LP), Limited Liability Company Agreement (Oasis Midstream Partners LP), Contribution and Simplification Agreement (Oasis Midstream Partners LP)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year taxable year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i) (1).
Appears in 4 contracts
Sources: Operating Agreement (News Communications Inc), Operating Agreement (Hollinger Nci Holdings LLC), Limited Liability Company Agreement (Peoples Liberation Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i).
Appears in 4 contracts
Sources: Operating Agreement (Collins Growth & Income Fund LLC), Operating Agreement (Collins Growth & Income Fund LLC), Operating Agreement (Collins Growth & Income Fund LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Sources: Limited Liability Company Agreement, Operating Agreement, Limited Liability Company Agreement (Public Service Co of New Hampshire)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Treasury Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1)attributable.
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Nextracker Inc.), Limited Liability Company Agreement (Nextracker Inc.), Framework Agreement (Evolve Transition Infrastructure LP)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i) (1).
Appears in 4 contracts
Sources: Operating Agreement (Anworth Mortgage Asset Corp), Limited Liability Company Agreement (Bunge LTD), Operating Agreement (Lodgenet Entertainment Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year year shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Motorsport Gaming Us LLC), Limited Liability Company Agreement (Motorsport Gaming Us LLC), Limited Liability Company Agreement (Capitala Finance Corp.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for ----------------------------- any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 3 contracts
Sources: Operating Agreement (Finova Group Inc), Limited Liability Company Agreement (Forest Bank LLC), Limited Liability Company Agreement (Forest Bank LLC)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Zentalis Pharmaceuticals, Inc.), Limited Liability Company Agreement (Zentalis Pharmaceuticals, LLC), Limited Liability Company Agreement (Zentalis Pharmaceuticals, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Regulations Section 1.704-2(i)(12(i).
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Chelsea Gca Realty Inc), Limited Liability Company Agreement (Chelsea Gca Realty Inc), Limited Liability Company Agreement (Chelsea Gca Realty Partnership Lp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation § 1.704-2(i)(12(i).
Appears in 3 contracts
Sources: Operating Agreement (Auor Capital Fund v LLC), Limited Liability Company Agreement (Genelux Corp), Operating Agreement (Inergy Pipeline East, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year taxable year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i).
Appears in 3 contracts
Sources: Limited Liability Company Agreement (Applied Digital Corp.), Limited Liability Company Agreement (Bluerock Residential Growth REIT, Inc.), Limited Liability Company Agreement (Bluerock Residential Growth REIT, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Deduction shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation section 1.704-2(i)(12(i).
Appears in 2 contracts
Sources: Operating Agreement (First American Capital Corp /Ks), Operating Agreement (First American Capital Corp /Ks)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Taxable Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Sources: Operating Agreement (KKR Financial Holdings LLC), Operating Agreement (KKR Financial Holdings LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Deduction shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section §1.704-2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (CHS Inc), Limited Liability Company Agreement (CHS Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall Deduction will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1Treasury Regulation § 1.704‑2(i).
Appears in 2 contracts
Sources: Operating Agreement (Aspen Mortgage Income Fund II, LLC), Limited Liability Company Agreement (IMH Financial Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(12(i).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Mach Natural Resources Lp), Limited Liability Company Agreement (Mach Natural Resources Lp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with 21 21 respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-1.704- 2(i)(1).
Appears in 2 contracts
Sources: Operating Agreement (Crescent Operating Inc), Operating Agreement (Crescent Operating Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Treasury Regulation Section 1.704-2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Noble Environmental Power LLC), Limited Liability Company Agreement (Noble Environmental Power LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Operating Agreement (SFX Entertainment, INC), Operating Agreement (Quigley Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Treasury Regulation Section 1.704-2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (At&t Inc.), Limited Liability Company Agreement (At&t Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company Year or other applicable period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Regulation § 1.704-2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Ashford Hospitality Trust Inc), Limited Liability Company Agreement (Ashford Hospitality Trust Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year fiscal year or other period shall be specially allocated to the Member Unit Holder who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Sources: Operating Agreement (Universal Outdoor Inc), Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Tax Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section section 1.704-2(i)(1)) of the Regulations.
Appears in 2 contracts
Sources: Restructuring Agreement, Restructuring Agreement (Health Management Associates Inc)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement (Onconova Therapeutics, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall Deduction will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation § 1.704-2(i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year or other period shall be specially allocated to the Member who that bears the economic risk of loss with respect to for the Member Nonrecourse Debt to in respect of which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section (as determined under Regulation Sections 1.704-2(i)(12(b)(4) and (i)(1)).
Appears in 1 contract
Sources: Operating Agreement (General Growth Properties Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(11.7042(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Majestic Funding Partners, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Sources: Operating Agreement (Wells Mid-Horizon Value-Added Fund I LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member or Members who bears bear the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Regulations Section 1.704-2(i)(1)) of the Treasury Regulations.
Appears in 1 contract
Sources: Limited Liability Company Agreement (Main Street Capital CORP)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears Members which bear the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation ss. 1.704-2(i)(12(i).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Cenex Harvest States Cooperatives)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Series B Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section § 1.704-2(i)(1).
Appears in 1 contract
Sources: Separate Series Operating Agreement (Rabble One, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year year shall be specially allocated to the Member or Members who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section §1.704-2(i)(1).
Appears in 1 contract
Sources: Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for ----------------------------- any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i) (1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i)(l).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Regulations Section 1.704-2(i)(11.704- 2(i).
Appears in 1 contract
Sources: Limited Liability Company Agreement (CNL Hospitality Properties Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Company year shall be specially allocated to the Member Member(s) who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable attributable, in accordance with Treasury Regulations Section 1.704-2(i)(12(i).
Appears in 1 contract
Sources: Agreement of Limited Liability Company (T&w Financial Corp)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation §1.704-2(i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section § 1.704-2(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (A-Power Energy Generation Systems, Ltd.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt liability to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Regulation Section 1.704-2(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Viant Technology Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such those Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treas. Reg. §1.704-2(i)(12(i)(l).
Appears in 1 contract
Sources: Limited Liability Company Agreement (NRG Retail LLC)
Member Nonrecourse Deductions. Any The Member Nonrecourse Deductions for any Allocation Year shall be specially allocated each year to the Member who that bears the economic risk of loss with respect to (within the meaning of Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section section 1.704-2(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Philadelphia Energy Solutions Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Company Year or other applicable period shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Regulation § 1.704-2(i)(12(i)(l).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Ashford Hospitality Trust Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i)(l).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Class A Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation § 1.704-2(i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall will be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation S 1.704-2(i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt loan to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treasury Regulation ss. 1.704-2(i)(12(i).
Appears in 1 contract
Sources: Operating Agreement (Tortoise Total Return Fund, LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who that bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions the deductions are attributable allocable in accordance with Regulations Regulation Section 1.704-2(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Carter Validus Mission Critical REIT, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(11.704 -2(i)(1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section Treas. Reg. §1.704-2(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (NRG Retail LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(i)(11.704‑2(i)(1).
Appears in 1 contract
Sources: Transaction Agreement (Apollo Global Management LLC)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions (as defined in Section 11(c) hereof) for any Allocation Year shall be specially allocated to the Member who bears the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i)(l).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Professional Teleconcepts, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions ----------------------------- for any Allocation Fiscal Year or other period shall be specially allocated to the Member who bears (or is deemed to bear) the economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Regulations Section 1.704-2(i)(12(i)(2).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions for any Allocation Year Period or other period shall be specially allocated to the Member who bears the economic risk of loss with respect to the liability to which the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are Deduction is attributable in accordance with Regulations Regulation Section 1.704-2(i)(11.704‑2(i).
Appears in 1 contract
Sources: Limited Liability Company Agreement