Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 11 contracts
Sources: Purchase and Sale Agreement (NRG Yield, Inc.), Purchase and Sale Agreement, Operating Agreement (Bloomin' Brands, Inc.)
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions (as defined in Regulations determined under Regulation Section 1.704-2(b)(12(c)) for any Fiscal Year or other period shall be specially allocated to among the Members in proportion to their Percentage Interests.
Appears in 8 contracts
Sources: Operating Agreement (Strategic Realty Trust, Inc.), Operating Agreement (Strategic Realty Trust, Inc.), Operating Agreement (Wellsford Real Properties Inc)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) Nonrecourse Deductions for any Fiscal Year or other period shall be specially allocated to the Members in proportion to each of their respective Percentage InterestsInterests in the Company. This provision is to be interpreted in a manner consistent with Regulation Sections 1.704-2(b)(1) and 1.704-2(e).
Appears in 8 contracts
Sources: Limited Liability Company Agreement (Phillips 66 Partners Lp), Limited Liability Company Agreement (Phillips 66 Partners Lp), Limited Liability Company Agreement (Phillips 66)
Nonrecourse Deductions. Any Notwithstanding Section 8.3.2, any nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) for any Fiscal Year fiscal year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 7 contracts
Sources: Limited Liability Company Agreement (RiceBran Technologies), Limited Liability Company Agreement (RiceBran Technologies), Membership Interest Purchase Agreement (Nutracea)
Nonrecourse Deductions. Any “nonrecourse deductions deductions” (as defined in Regulations Treasury Regulation Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to among the Members in proportion to accordance with their Percentage Interests.
Appears in 6 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement (KBS Strategic Opportunity REIT II, Inc.)
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 5 contracts
Sources: Operating Agreement (Wiprosper Ventures, LLC), Limited Liability Company Agreement (Vince Holding Corp.), Membership Interest Purchase Agreement (XCel Brands, Inc.)
Nonrecourse Deductions. Any nonrecourse deductions “Nonrecourse deductions” (as that term is defined in Regulations Section Sections 1.704-2(b)(1)) and (c) of the Regulations) for any Fiscal Year or other period shall be specially allocated to the Members Partners in proportion to their Percentage Interests.
Appears in 5 contracts
Sources: Limited Partnership Agreement (Wcof, LLC), Limited Partnership Agreement (Sk Telecom Co LTD), Limited Partnership Agreement (Virgin Mobile USA, Inc.)
Nonrecourse Deductions. Any nonrecourse deductions “Nonrecourse deductions” (as that term is defined in Regulations Section Sections 1.704-2(b)(1)) and (c) of the Regulations) for any Fiscal Year or other taxable period shall be specially allocated to the Members in proportion to their Percentage Intereststhe number of Units each holds.
Appears in 5 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement (American Medical Alert Corp), Limited Liability Company Agreement (HUGHES Telematics, Inc.)
Nonrecourse Deductions. Any nonrecourse deductions (deductions, as defined in Regulations Section 1.704-2(b)(1)) , for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 4 contracts
Sources: Operating Agreement (Dover Investments Corp), Operating Agreement (Dover Investments Corp), Operating Agreement (Dover Investments Corp)
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions, if any, for any Fiscal Year shall be allocated (as defined in nearly as possible) under Treasury Regulations Section 1.704-2(b)(1)2(e) for any Fiscal Year or other period shall be specially allocated to among the Members in proportion to their respective Percentage Interests.
Appears in 4 contracts
Sources: Limited Liability Company Agreement (United Auto Group Inc), Limited Liability Company Agreement (HBL LLC), Limited Liability Company Agreement (United Auto Group Inc)
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Common Members in proportion to their Percentage Intereststhe Units held by such Common Members.
Appears in 3 contracts
Sources: Operating Agreement (Vinco Ventures, Inc.), Operating Agreement (Xspand Products Lab, Inc.), Operating Agreement (Xspand Products Lab, Inc.)
Nonrecourse Deductions. Any Notwithstanding Section 6.1, any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 3 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement (Imperial Capital Group, Inc.), Limited Liability Company Agreement (Imperial Capital Group, Inc.)
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions (as defined and determined in Regulations Section Sections 1.704-2(b)(12(b) and 1.704-2(c)) for any Fiscal Year or other period shall be specially allocated to among the Members in proportion to their Common Percentage InterestsInterests except to the extent that applicable Regulations require that such deductions be allocated in some other manner.
Appears in 3 contracts
Sources: Operating Agreement (Diamond Resorts Corp), Operating Agreement (Diamond Resorts Corp), Operating Agreement (Diamond Resorts Parent, LLC)
Nonrecourse Deductions. Any Notwithstanding Section 6.1, any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall will be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 2 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement (Provision Holding, Inc.)
Nonrecourse Deductions. Any Notwithstanding Section 6.1, any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(12(b)(l)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 2 contracts
Sources: Operating Agreement, Operating Agreement
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse deductions" (as that term is defined in Regulations Section Sections 1.704-2(b)(1)) and (c) of the Regulations) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their respective Percentage InterestsInterests in the Company.
Appears in 2 contracts
Sources: Operating Agreement (Sunrise Assisted Living Inc), Operating Agreement (Sunrise Assisted Living Inc)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section 1.7041. 704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 2 contracts
Sources: Operating Agreement (Dover Investments Corp), Operating Agreement (Dover Investments Corp)
Nonrecourse Deductions. Any nonrecourse deductions “Nonrecourse deductions” (as that term is defined in Treasury Regulations Section Sections 1.704-2(b)(1) and (c)) for any Fiscal Allocation Year or other period shall will be specially allocated to the Members in proportion to their respective Percentage Interests.
Appears in 2 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement (Exco Resources Inc)
Nonrecourse Deductions. Any nonrecourse deductions non-recourse deduction (as defined in Regulations Section § 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their respective Percentage Interests.
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Limoneira CO), Contribution Agreement (Limoneira CO)
Nonrecourse Deductions. Any Notwithstanding Section 6.1, any ---------------------- nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Membership Interests.
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Point West Capital Corp), Limited Liability Company Agreement (Point West Capital Corp)
Nonrecourse Deductions. Any nonrecourse deductions (Nonrecourse Deductions, as that term is defined in Regulations Section 1.704-2(b)(1)) of the Treasury Regulations, for any Fiscal Year Allocation Period or other period shall be specially allocated to among the Members in proportion to their respective Percentage Interests.
Appears in 2 contracts
Sources: Limited Liability Company Agreement (Mach Natural Resources Lp), Limited Liability Company Agreement (Mach Natural Resources Lp)
Nonrecourse Deductions. Any nonrecourse deductions (as defined ---------------------- in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 2 contracts
Sources: Operating Agreement (Auto Marketing Network Inc), Operating Agreement (Franchise Mortgage Acceptance Co)
Nonrecourse Deductions. Any Notwithstanding Section 6.1 above, any nonrecourse deductions (as defined in Regulations Section Regs § 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.Interests as provided in Exhibit B.
Appears in 2 contracts
Sources: Operating Agreement (Molecular Imaging Corp), Operating Agreement (Molecular Imaging Corp)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section § 1.704-2(b)(12(b)(l)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests. 7.
Appears in 1 contract
Sources: Operating Agreement
Nonrecourse Deductions. Any Notwithstanding Section 6.1, any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their respective Percentage Interests.
Appears in 1 contract
Nonrecourse Deductions. Any Notwithstanding Sections 6.3 and 6.4, any nonrecourse deductions (as defined in Regulations Section §1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 1 contract
Sources: Operating Agreement (Red Rock Pictures Holdings, Inc)
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions (as defined in and determined under the principles of Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interestsrespective Membership Percentages.
Appears in 1 contract
Sources: Limited Liability Company Agreement (AGCO International GmbH)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their then respective Percentage Interests.
Appears in 1 contract
Sources: Operating Agreement (First American Financial Corp)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members and Economic Interest Owners in proportion to their Percentage Interests.
Appears in 1 contract
Sources: Limited Liability Company Agreement (Solar Power, Inc.)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(12(b)(l)) for any Fiscal Year fiscal year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 1 contract
Sources: Operating Agreement (Kw 2012 C, LLC)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(12 (b) (1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 1 contract
Nonrecourse Deductions. Any Notwithstanding Section 6.4, any nonrecourse deductions (as defined in Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Class Percentage Interests.
Appears in 1 contract
Sources: Limited Liability Company Agreement
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section §1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 1 contract
Sources: Operating Agreement
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) for any Fiscal Year fiscal year or other period shall be specially specifically allocated to the Members in proportion to their Percentage Interests.
Appears in 1 contract
Sources: Operating Agreement
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their respective Percentage Interests.
Appears in 1 contract
Sources: Limited Liability Company Agreement
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions (as defined in Regulations Section §1.704-2(b)(1)2(b)(l) and §1.704-2(c) of the Regulations) for any Fiscal Year or other period fiscal year shall be specially allocated to among the Members in proportion to their Percentage Interests.
Appears in 1 contract
Sources: Limited Liability Company Agreement (Medical Properties Trust, LLC)
Nonrecourse Deductions. Any nonrecourse deductions Nonrecourse Deductions (as defined which shall have the meaning set forth in Regulations Section 1.704-2(b)(1)) of the Regulations and which shall be determined in accordance with Section 1.704-2(c) of the Regulations) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage InterestsMembership Interests at that time.
Appears in 1 contract
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations ---------------------- Regulations
Section 1.7041. 704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their then respective Percentage Interests.
Appears in 1 contract
Sources: Operating Agreement (First American Financial Corp)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Treasury Regulations Section 1.704-2(b)(1)) for any Fiscal Year fiscal year or other period shall be specially specifically allocated to the Members in proportion to their Percentage Membership Interests.
Appears in 1 contract
Nonrecourse Deductions. Any nonrecourse deductions “Nonrecourse deductions” (as such term is defined in Regulations Section 1.704-2(b)(12(b)) for any Fiscal Year or other period Period shall be specially allocated to among the Members Partners in proportion to their Percentage InterestsInterests or as otherwise required by such Regulations Section.
Appears in 1 contract
Sources: Limited Partnership Agreement (PJC Manchester Realty LLC)
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section § 1.704-2(b)(12(b)(l)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their Percentage Interests.
Appears in 1 contract
Nonrecourse Deductions. Any nonrecourse Nonrecourse deductions (as such term is defined in Regulations Section 1.704-2(b)(12(b)) ), if any, for any Fiscal Year taxable year or other period shall be specially allocated to among the Members in proportion to their accordance with the Members' Percentage Interests.
Appears in 1 contract
Nonrecourse Deductions. Any nonrecourse deductions (as defined in Regulations Section § 1.704-2(b)(1)) for any Fiscal Year or other period shall be specially allocated to the Members in proportion to their then respective Percentage Interests.
Appears in 1 contract
Nonrecourse Deductions. Any nonrecourse deductions (as defined designed in Treasury Regulations Section 1.704-2(b)(12(b) (1)) for any Fiscal Year fiscal year or other period shall be specially allocated to the Members in proportion to their Percentage Membership Interests.
Appears in 1 contract
Sources: Operating Agreement