Member Nonrecourse Deductions. Member Nonrecourse Deductions shall be allocated among the Members who bear the Economic Risk of Loss for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Regulations Section 1.704-2(b)(4) and (i)(1).
Appears in 7 contracts
Sources: Limited Liability Company Agreement (Vince Holding Corp.), Membership Interest Purchase Agreement (XCel Brands, Inc.), Operating Agreement (Xspand Products Lab, Inc.)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement, any Member Nonrecourse Deductions shall be specially allocated among to the Members who bear the Economic Risk economic risk of Loss for loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions items are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Treasury Regulations Section 1.704-2(b)(4) and (i)(12(i).
Appears in 7 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement (Paradyme Fund a Ii, LLC)
Member Nonrecourse Deductions. Member Nonrecourse Deductions shall will be allocated among to the Members who that bear the Economic Risk economic risk of Loss loss (within the meaning of Treasury Regulations Section 1.752-2) for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Regulations Section 1.704-2(b)(4) and (i)(1)attributable.
Appears in 6 contracts
Sources: Limited Liability Company Agreement (Crestwood Midstream Partners LP), Limited Liability Company Agreement, Limited Liability Company Agreement (Crestwood Midstream Partners LP)
Member Nonrecourse Deductions. Notwithstanding anything to the contrary in this Agreement, any Member Nonrecourse Deductions shall for any Fiscal Year or other period for which allocations are made will be allocated among to the Members Member who bear bears the Economic Risk economic risk of Loss for loss with respect to the Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Regulations Regulation Section 1.704-2(b)(4) and (i)(12(i).
Appears in 5 contracts
Sources: Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.), Operating Agreement (HTS-Sunset Harbor Partner, L.L.C.), Operating Agreement (Jack Miller Family Limited Partnership 1)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated among the Members who bear the Economic Risk of Loss for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of (as defined under Regulations Section 1.704-2(b)(42(i)(2)) and (i)(1)shall be allocated pursuant to Regulations Section 1.704-2(i)(1) to the Member who bears the economic risk of loss with respect to the “Member Nonrecourse Debt” to which it is attributable.
Appears in 4 contracts
Sources: Operating Agreement (Diamond Resorts Corp), Operating Agreement (Diamond Resorts Corp), Operating Agreement (155 East Tropicana, LLC)
Member Nonrecourse Deductions. In accordance with the provisions of Treasury Regulation Section 1.704-2(i), each item of Member Nonrecourse Deductions Deduction shall be allocated among the Members who in proportion to the economic risk of loss that the Members bear with respect to the Economic Risk nonrecourse liability of Loss for the Member Nonrecourse Debt Company to which such item of Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision Deduction is to be interpreted in a manner consistent with the requirements of Regulations Section 1.704-2(b)(4) and (i)(1)attributable.
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Maxygen Inc), Limited Liability Company Agreement (Maxygen Inc), Operating Agreement (Liveworld Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated among the Members who bear the Economic Risk of Loss for to the Member Nonrecourse Debt who bears the risk of loss with respect to the loan to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Regulations Section Treasury Regulation § 1.704-2(b)(4) and (i)(12(i).
Appears in 4 contracts
Sources: Operating Agreement, Operating Agreement, Operating Agreement (West Corp)
Member Nonrecourse Deductions. All Member Nonrecourse Deductions attributable to Member Nonrecourse Debt shall be allocated among the Members who bear bearing the Economic Risk of Loss for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner debt consistent with the requirements of Regulations Section 1.704-2(b)(42(i)(1) and (i)(1)of the Regulations.
Appears in 4 contracts
Sources: Limited Liability Company Agreement (Skechers Usa Inc), Limited Liability Company Agreement (Skechers Usa Inc), Limited Liability Company Agreement (Skechers Usa Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated among to the Members who bear Member that bears the Economic Risk of Loss for the Member Nonrecourse Debt member nonrecourse debt to which such Member Nonrecourse Deductions are attributable deductions relate as provided in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Regulations Treasury Regulation Section 1.704-2(b)(4) and (i)(11.7042(i)(1).
Appears in 3 contracts
Sources: Limited Liability Company Agreement (KPMG Consulting Inc), Limited Liability Company Agreement (KPMG Consulting Inc), Limited Liability Company Agreement (KPMG Consulting Inc)
Member Nonrecourse Deductions. Member Nonrecourse Deductions shall be allocated among to the Members Member who bear bears the Economic Risk economic risk of Loss for loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable relate in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Treasury Regulations Section 1.704-2(b)(4) and (i)(12(i).; and
Appears in 2 contracts
Sources: Master Purchase and Sale Agreement (Plum Creek Timber Co Inc), Master Purchase and Sale Agreement (MEADWESTVACO Corp)
Member Nonrecourse Deductions. Notwithstanding any provision hereof to the contrary, any Member Nonrecourse Deductions shall be specially allocated among the Members who bear the Economic Risk of Loss for to the Member who bears the economic risk of loss with respect to the Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Regulations Section 1.704-2(b)(4) and (i)(12(i)(1).
Appears in 2 contracts
Sources: Operating Agreement (Moody National REIT I, Inc.), Operating Agreement (Moody National REIT I, Inc.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated among to the Members Member who bear bears the Economic Risk of Loss for with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debtaccordance with Treasury Regulations Section 1.704-2(i)(1). This provision is to be interpreted in a manner consistent with the requirements of Regulations Section 1.704-2(b)(4) and (i)(1)) of the Treasury Regulations.
Appears in 2 contracts
Sources: Joint Venture Operating Agreement (Grown Rogue International Inc.), Limited Liability Company Operating Agreement
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall will be specially allocated among to the Members who bear Member that bears the Economic Risk of Loss for the Member Nonrecourse Debt member nonrecourse debt to which such Member Nonrecourse Deductions are attributable deductions relate as provided in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Treasury Regulations Section 1.704-2(b)(4) and (i)(12(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Simon Worldwide Inc), Limited Liability Company Agreement (Simon Worldwide Inc)
Member Nonrecourse Deductions. Notwithstanding anything to the contrary in this Agreement, any Member Nonrecourse Deductions for any taxable year or other period for which allocations are made shall be allocated among to the Members Member who bear bears the Economic Risk economic risk of Loss for loss with respect to the Member Nonrecourse Debt to which such the Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Regulations Section 1.704-2(b)(4) and (i)(12(i).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Cb Richard Ellis Realty Trust), Limited Liability Company Agreement (Cb Richard Ellis Realty Trust)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated among to the Members Member who bear bears the Economic Risk economic risk of Loss for loss (within the meaning of Treasury Regulations Section 1.752-2) with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Regulations and as required by Treasury Regulation Section 1.704-2(b)(4) and (i)(12(i)(1).
Appears in 2 contracts
Sources: Limited Liability Company Agreement (DJSP Enterprises, Inc.), Limited Liability Company Agreement (Chardan 2008 China Acquisition Corp.)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall will be allocated among to the Members who bear Member that takes the Economic Risk of Loss for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable deductions relate as provided in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Regulations Treasury Regulation Section 1.704-2(b)(4) and (i)(12(i)(1).
Appears in 2 contracts
Sources: Operating Agreement (Playboy Enterprises Inc), Operating Agreement (Claxson Interactive Group Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated among to the Members who bear Member that takes the Economic Risk of Loss for the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable deductions relate as provided in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Regulations Treasury Regulation Section 1.704-2(b)(4) and (i)(12(i)(1).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be specially allocated among to the Members Member who bear bears the Economic Risk economic risk of Loss for loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Treasury Regulations Section 1.704l.704-2(b)(4) and (i)(12(i).
Appears in 1 contract
Sources: Operating Agreement (Bespoke Capital Acquisition Corp)
Member Nonrecourse Deductions. Notwithstanding any other provision of this Agreement to the contrary, any Member Nonrecourse Deductions shall will be allocated among the Members who bear the Economic Risk of Loss for to the Member Nonrecourse Debt who (in his, her or its capacity, directly or indirectly, as lender, guarantor, or otherwise) bears the economic risk of loss with respect to the loan to which such Member Nonrecourse Deductions partner nonrecourse deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Treasury Regulations Section 1.704-2(b)(4) and (i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions Deduction shall be allocated among the Members who bear the Economic Risk of Loss for to the Member Nonrecourse Debt who bears the risk of loss with respect to the loan to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Treasury Regulations Section 1.704ss.1.704-2(b)(4) and (i)(12(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Cenex Harvest States Cooperatives)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall be allocated among the Members who bear the Economic Risk of Loss for to the Member Nonrecourse Debt that bears the risk of loss with respect to the loan to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Regulations Section 1.704Treasury Regulation (S)1.704-2(b)(4) and (i)(12(i).
Appears in 1 contract
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions shall will be allocated among to the Members who bear Member that bears the Economic Risk of Loss for the Member Nonrecourse Debt member nonrecourse debt to which such Member Nonrecourse Deductions are attributable deductions relate as provided in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent with the requirements of Regulations Treasury Regulation Section 1.704-2(b)(4) and (i)(12(i)(1).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Genius Products Inc)
Member Nonrecourse Deductions. Any Member Nonrecourse Deductions Deduction shall be allocated among the Members who bear the Economic Risk of Loss for to the Member Nonrecourse Debt who bears the risk of loss with respect to the loan to which such Member Nonrecourse Deductions are attributable in the ratio in which they share Economic Risk of Loss for such Member Nonrecourse Debt. This provision is to be interpreted in a manner consistent accordance with the requirements of Regulations Section Treasury Regulation § 1.704-2(b)(4) and (i)(12(i).
Appears in 1 contract