Epstein Files Search

EFTA01134802Set 9

2013-05-0137p14,486w

partner nonrecourse debt set forth in Treasury Regulation § 1.704-2(b)(4). "Member Nonrecourse Deductions" shall have the same meaning as partner nonrecourse deductions set forth in Treasury Regulation ... Generally, the amount of Member Nonrecourse Deductions with respect to a Member Nonrecourse Debt for a fiscal year equals the net increase during the year in the amount of Member ... Member Minimum Gain, determined according to the provisions of Treasury Regulation § 1.704-2(i). "Nonrecourse Deduction" shall have the same meaning as nonrecourse deductions set forth in Treasury Regulation

https://www.justice.gov/epstein/files/DataSet%209/EFTA01134802.pdf

EFTA00284039Set 9

17p7,814w

Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3). "Member Nonrecourse Deductions" has the same meaning as the term "partner nonrecourse deductions" set forth in Regulations Sections ... Special Allocations. Notwithstanding anything to the contrary contained in this Exhibit B: Nonrecourse Deductions. Nonrecourse Deductions shall be allocated to the Members pro rata, in accordance with their Percentage Interests ... Member Nonrecourse Deductions. Member Nonrecourse Deductions shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member Nonrecourse Deductions

https://www.justice.gov/epstein/files/DataSet%209/EFTA00284039.pdf

EFTA00284022Set 9

17p7,814w

Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(i)(3). "Member Nonrecourse Deductions" has the same meaning as the term "partner nonrecourse deductions" set forth in Regulations Sections ... Special Allocations. Notwithstanding anything to the contrary contained in this Exhibit B: Nonrecourse Deductions. Nonrecourse Deductions shall be allocated to the Members pro rata, in accordance with their Percentage Interests ... Member Nonrecourse Deductions. Member Nonrecourse Deductions shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member Nonrecourse Deductions

https://www.justice.gov/epstein/files/DataSet%209/EFTA00284022.pdf

EFTA00806988Set 9

16p7,568w

Nonrecourse Liability, determined in accordance with Regulations Section 1.704-2(iX3). (.1) "Member Nonrecourse Deductions" has the same meaning as the term "partner nonrecourse deductions" set forth in Regulations Sections ... Special Allocations. Notwithstanding anything to the contrary contained in this Exhibit A: (a) Nonrecourse Deductions. Nonrecourse Deductions shall be allocated to the Members pro rata, in accordance with their Percentage ... Interests. (b) Member Nonrecourse Deductions. Member Nonrecourse Deductions shall be allocated to the Member who bears the economic risk of loss with respect to the liability to which such Member

https://www.justice.gov/epstein/files/DataSet%209/EFTA00806988.pdf

EFTA00617557Set 9

78p41,041w

Section 4.2 shall be excluded from the determination of Net Profit or Net Loss. "Nonrecourse Deductions" shall have the meaning set forth in Treasury Regulations Sections ... Partner bears the economic risk of loss, as determined under applicable Treasury Regulations. "Partner Nonrecourse Deductions" shall mean the amount of deductions, losses and expenses equal to the net increase ... Minimum Gain attributable to a Partner Nonrecourse Debt that gives rise to Partner Nonrecourse Deductions, each Partner bearing the economic risk of loss for such Partner Nonrecourse Debt shall

https://www.justice.gov/epstein/files/DataSet%209/EFTA00617557.pdf

EFTA01084769Set 9

78p41,041w

Section 4.2 shall be excluded from the determination of Net Profit or Net Loss. "Nonrecourse Deductions" shall have the meaning set forth in Treasury Regulations Sections ... Partner bears the economic risk of loss, as determined under applicable Treasury Regulations. "Partner Nonrecourse Deductions" shall mean the amount of deductions, losses and expenses equal to the net increase ... Minimum Gain attributable to a Partner Nonrecourse Debt that gives rise to Partner Nonrecourse Deductions, each Partner bearing the economic risk of loss for such Partner Nonrecourse Debt shall

https://www.justice.gov/epstein/files/DataSet%209/EFTA01084769.pdf

EFTA00614617Set 9

2015-03-0942p11,172w

hereof shall not be taken into account in computing Net Income or Net Losses. "Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXiv) hereof. "Partner Nonrecourse Debt Minimum ... Gain" has the meaning set forth in Section 5.08(bXi). "Partner Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXv) hereof "Partners" means, as the context may require ... bXii) and this Section 5.08(b)(iii) were not in this Agreement. (iv) Nonrecourse Deductions. "Nonrecourse Deductions" as defined in Treasury Regulations Section 1.704-2(b), shall be allocated

https://www.justice.gov/epstein/files/DataSet%209/EFTA00614617.pdf

EFTA01084507Set 9

2006-12-0649p19,072w

made as if this Section I .02(c) were not in the Agreement. (d) Nonrecourse Deductions. Nonrecourse deductions for any fiscal year shall be allocated to the Members pro rata ... accordance with their respective Equity Percentages. (e) Partner Nonrecourse Deductions. Partner nonrecourse deductions for any Fiscal Year shall be specially allocated to the Member who bears the economic risk ... risk of loss, with respect to the partner nonrecourse debt to which such partner nonrecourse deductions are attributable in accordance with Section 1.704-2(i)( I ) of the Regulations

https://www.justice.gov/epstein/files/DataSet%209/EFTA01084507.pdf

EFTA00614659Set 9

2015-03-0942p11,174w

hereof shall not be taken into account in computing Net Income or Net Losses. "Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXiv) hereof. "Partner Nonrecourse Debt Minimum ... Gain" has the meaning set forth in Section 5.08(bXi). "Partner Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXv) hereof "Partners" means, as the context may require ... bXii) and this Section 5.08(b)(iii) were not in this Agreement. (iv) Nonrecourse Deductions. "Nonrecourse Deductions" as defined in Treasury Regulations Section 1.704-2(b), shall be allocated

https://www.justice.gov/epstein/files/DataSet%209/EFTA00614659.pdf

EFTA00803515Set 9

2015-03-0942p18,911w

hereof shall not be taken into account in computing Net Income or Net Losses. "Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXiv) hereof. "Partner Nonrecourse Debt Minimum ... Gain" has the meaning set forth in Section 5.08(bXi). "Partner Nonrecourse Deductions" has the meaning set forth in Section 5.08(bXv) hereof "Partners" means, as the context may require ... bXii) and this Section 5.08(b)(iii) were not in this Agreement. (iv) Nonrecourse Deductions. "Nonrecourse Deductions" as defined in Treasury Regulations Section 1.704-2(b), shall be allocated

https://www.justice.gov/epstein/files/DataSet%209/EFTA00803515.pdf

EFTA00312828Set 9

2012-10-1924p8,275w

Allocations to the Member of Losses. (d) Allocations to the Member of deductions, expenses, Nonrecourse Deductions and net losses allocated to him pursuant to this Agreement, and the Member ... aX2XB) or are treated as such expenditures under Treasury Regulation Section 1.704-1(bX2XivXi). "Nonrecourse Deductions" shall have the meaning set forth in Treasury Regulation Section 1.704-2. 3 EFTA00312830 ... Allocations to the Member of Losses. (d) Allocations to the Member of deductions, expenses, Nonrecourse Deductions and net losses allocated to him pursuant to this Agreement, and the Member

https://www.justice.gov/epstein/files/DataSet%209/EFTA00312828.pdf

EFTA01093471Set 9

38p18,496w

Section 5.3(b) and this Section 5.3(c) were not in this Agreement. (d) Nonrecourse Deductions. Nonrecourse Deductions shall be allocated to the Members in proportion to their Capital Contributions ... with respect to the related Portfolio Investment. (e) Member Nonrecourse Deductions. Member Nonrecourse Deductions for any Fiscal Period shall be allocated to the Member who bears the economic risk ... loss with respect to the liability to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j). CRYPTD CURRENCI" PARTNERT 11,11-C Operating

https://www.justice.gov/epstein/files/DataSet%209/EFTA01093471.pdf

EFTA00742409Set 9

2007-11-149p4,663w

Unit holder or related party), such loss or deduction (referred to as a "partner nonrecourse" deduction or loss) shall be allocated to the Unit holders that bear the economic risk ... rules. Under the Sample Freeze Agreement, any Unit holder that is allocated a nonrecourse deduction or loss or a partner nonrecourse deduction or loss from the Freeze Entity shall

https://www.justice.gov/epstein/files/DataSet%209/EFTA00742409.pdf

EFTA01093509Set 9

40p19,567w

Section 5.3(b) and this Section 5.3(c) were not in this Agreement. (c0 Nonrecourse Deductions. Nonrecourse Deductions shall be allocated to the Partners in proportion to their Capital Contributions ... with respect to the related Portfolio Investment. (e) Partner Nontreourre Deductions. Partner Nonrecourse Deductions for any Fiscal Period shall be allocated to the Partner who bears the economic risk ... loss with respect to the liability to which such Partner Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704-2(j). (0 Curative Allocations. If any special allocations

https://www.justice.gov/epstein/files/DataSet%209/EFTA01093509.pdf

EFTA01355359Set 10

1p558w

Treasury Regulation Section 1.704-2(f) and Treasury Regulation Section 1.704-2(iX4). 1.2 Nonrecourse Deductions. All "nonrecourse deductions" (as defined in Treasury Regulation Section ... allocated to the Partners in accordance with their respective Contributions: provided. however, that nonrecourse deductions attributable to "partner nonrecourse debt" (as defined in Treasury Regulation Section

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01355359.pdf

EFTA01391350Set 10

1p556w

Treasury Regulation Section 1.704-2(f) and Treasury Regulation Section 1.704-2(iX4). 1.2 Nonrecourse Deductions. All "nonrecourse deductions" (as defined in Treasury Regulation Section ... allocated to the Partners in accordance with their respective Contributions: provided. however, that nonrecourse deductions attributable to "partner nonrecourse debt" (as defined in Treasury Regulation Section

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01391350.pdf

EFTA01392337Set 10

1p557w

Treasury Regulation Section 1.704-2(f) and Treasury Regulation Section 1.704-2(iX4). 1.2 Nonrecourse Deductions. All "nonrecourse deductions" (as defined in Treasury Regulation Section ... allocated to the Partners in accordance with their respective Contributions: provided. however, that nonrecourse deductions attributable to "partner nonrecourse debt" (as defined in Treasury Regulation Section

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01392337.pdf

EFTA01389674Set 10

1p555w

Treasury Regulation Section 1.704-2(f) and Treasury Regulation Section 1.704-2(iX4). 1.2 Nonrecourse Deductions. All "nonrecourse deductions" (as defined in Treasury Regulation Section ... allocated to the Partners in accordance with their respective Contributions: provided. however, that nonrecourse deductions attributable to "partner nonrecourse debt" (as defined in Treasury Regulation Section

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01389674.pdf

EFTA01364671Set 10

1p557w

Treasury Regulation Section 1.704-2(f) and Treasury Regulation Section 1.704-2(iX4). 1.2 Nonrecourse Deductions. All "nonrecourse deductions" (as defined in Treasury Regulation Section ... allocated to the Partners in accordance with their respective Contributions: provided. however, that nonrecourse deductions attributable to "partner nonrecourse debt" (as defined in Treasury Regulation Section

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01364671.pdf

EFTA01354588Set 10

1p557w

Treasury Regulation Section 1.704-2(f) and Treasury Regulation Section 1.704-2(iX4). 1.2 Nonrecourse Deductions. All "nonrecourse deductions" (as defined in Treasury Regulation Section ... allocated to the Partners in accordance with their respective Contributions: provided. however, that nonrecourse deductions attributable to "partner nonrecourse debt" (as defined in Treasury Regulation Section

https://www.justice.gov/epstein/files/DataSet%2010/EFTA01354588.pdf