Epstein Secrets

pital Account Deficit, pro rata, in proportion to their Capital Account balances, adjusted as provided in clauses (i) and (ii) of the definition of Adjusted Capital Account Deficit, until no Member would be entitled to any further allocation, and, thereafter, to all Members, pro rata, in proportion to their resp

with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if the Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3). "Member Nonrecourse Deductions" has the same meaning as the term "partner nonrec

pital Account Deficit, pro rata, in proportion to their Capital Account balances, adjusted as provided in clauses (i) and (ii) of the definition of Adjusted Capital Account Deficit, until no Member would be entitled to any further allocation, and, thereafter, to all Members, pro rata, in proportion to their resp

with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if the Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3). "Member Nonrecourse Deductions" has the same meaning as the term "partner nonrec

Account the items described in Regulations Sections 1.704-1(bX2XiiXdX4), 1.704-1(bX2XiiXdX5) and 1.704-1(bX2Xii)(dX6). The foregoing definition of Adjusted Capital Account Deficit is intended to comply with the provisions of Regulations Section 1.704-1(bX2XiiXd) and shall be interpreted consistently therewith.

with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section l.704-2(i)(3). "Member Nonrecourse Deductions" has the meaning of Partner Nonrecourse Deductions

nt the items described in Regulations Sections 1.704-1(bX2)(iiXdX4), 1.704-1(b)(2Xii)(d)(5) and 1.704-1(b)(2)(ii)(dX6). The foregoing definition of Adjusted Capital Account Deficit is intended to comply with the provisions of Regulations Section 1.704-1(bX2Xii)(d) and shall be interpreted consistently therewith

with respect to each Member Nonrecourse Debt, equal to the Company Minimum Gain that would result if such Member Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(iX3). "Member Nonrecourse Deductions" has the meaning of Partner Nonrecourse Deductions