Risk of Loss Allocation. Any item of Member Nonrecourse Deduction (as defined in Regulation Section 1.704-2(i)(2)) with respect to a Member Nonrecourse Debt (as defined in Regulation Section 1.704-2(b)(4)) shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Regulations Section 1.704-2(i)(1).
Appears in 4 contracts
Sources: Operating Agreement (Ballantyne of Omaha Inc), Limited Liability Company Agreement (Metropolis Realty Holdings LLC), Limited Liability Company Agreement (Metropolis Realty Trust Inc)
Risk of Loss Allocation. Any item of Member Nonrecourse Deduction (as defined in Regulation Section 1.704-2(i)(2)) with respect to a Member Nonrecourse Debt (as defined in Regulation Section 1.704-2(b)(4)) shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Regulations Section 1.704-2(i)(12(i)(l).
Appears in 2 contracts
Sources: Operating Agreement (RealD Inc.), Operating Agreement (RealD Inc.)
Risk of Loss Allocation. Any item of Member Nonrecourse Deduction “member nonrecourse deduction” (as defined in Treasury Regulation Section 1.704-2(i)(2)) with respect to a Member Nonrecourse Debt “member nonrecourse debt” (as defined in Treasury Regulation Section 1.704-2(b)(4)) shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt in accordance with Treasury Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Risk of Loss Allocation. Any item of Member Nonrecourse Deduction nonrecourse deduction (as defined in Regulation Section 1.704-2(i)(2)) with respect to a Member Nonrecourse Debt nonrecourse debt (as defined in Regulation Section 1.704-2(b)(4)) shall be allocated to the Member or Members who bear the economic risk of loss for such Member Nonrecourse Debt nonrecourse debt in accordance with Regulations Section 1.704-2(i)(1).
Appears in 1 contract
Sources: Operating Agreement (Newgold Inc)