Nonrecourse Debt. Losses attributable to a partner nonrecourse debt (as defined in Treasury Regulation section 1.704-2(b)(4)) will be allocated in the manner required by Treasury Regulation section 1.704-2(i)). If there is a net decrease during a Fiscal Year in partner nonrecourse debt minimum gain (as defined in Treasury Regulation section 1.704-3(i)(3)), then Profits for such Fiscal Year (and, if necessary, for subsequent Fiscal Years) shall be allocated to the Members in the amounts and of such character as determined according to, and subject to the exceptions contained in, Treasury Regulation section 1.704-2(i)(4).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Muzak Holdings Finance Corp)
Nonrecourse Debt. Losses attributable to a partner nonrecourse ---------------- debt (as defined in Treasury Regulation section Section 1.704-2(b)(4)) will be allocated in the manner required by Treasury Regulation section Section 1.704-2(i)). If there is a net decrease during a Fiscal Year in partner nonrecourse debt minimum gain (as defined in Treasury Regulation section Section 1.704-3(i)(32(i)(3)), then Profits for such Fiscal Year (and, if necessary, for subsequent Fiscal Years) shall will be allocated to the Members in the amounts and of such character as determined according to, and subject to the exceptions contained in, Treasury Regulation section 1.704-Section 1.704- 2(i)(4).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Muzak Finance Corp)
Nonrecourse Debt. Losses attributable to a partner nonrecourse ---------------- debt (as defined in Treasury Regulation section 1.704-2(b)(4)) will be allocated in the manner required by Treasury Regulation section 1.704-2(i)). If there is a net decrease during a Fiscal Year in partner nonrecourse debt minimum gain (as defined in Treasury Regulation section 1.704-3(i)(3)), then Profits for such Fiscal Year (and, if necessary, for subsequent Fiscal Years) shall be allocated to the Members in the amounts and of such character as determined according to, and subject to the exceptions contained in, Treasury Regulation section 1.704-2(i)(4).
Appears in 1 contract
Sources: Limited Liability Company Agreement (Muzak Finance Corp)