Excess Nonrecourse Liabilities. Pursuant to Regulations Section 1.752-3(a)(3), for the purpose of determining each Partner’s share of excess Nonrecourse Liabilities of the Partnership, and solely for such purpose, each Partner’s interest in Partnership profits shall be determined by any reasonable method chosen by the General Partner.
Appears in 4 contracts
Samples: Agreement (MGM Growth Properties LLC), MGM Growth Properties Operating Partnership LP, MGM Growth Properties LLC
Excess Nonrecourse Liabilities. Pursuant to Regulations Section 1.752-3(a)(3), for the purpose of determining each Partner’s share of excess Nonrecourse Liabilities nonrecourse liabilities of the Partnership, and solely for such purpose, each Partner’s interest in Partnership profits shall be determined by any reasonable method chosen by the General PartnerPartner including, without limitation, the principles set forth in Rev. Rul. 95-41, 1995-1 C.B. 132.
Appears in 3 contracts
Samples: Agreement (Seritage Growth Properties), Agreement (Seritage Growth Properties), Agreement (Seritage Growth Properties)
Excess Nonrecourse Liabilities. Pursuant to Regulations Section 1.752-3(a)(3), for For the purpose of determining each Partner’s 's share of excess Nonrecourse Liabilities nonrecourse liabilities of the Partnership, and solely for such purpose, each Partner’s 's interest in Partnership profits shall be reasonably determined by any reasonable method chosen by the General Partner.Managing Partner in accordance with Internal Revenue Service authority interpreting Regulations Section 1.752-3(a)(3). (5)
Appears in 2 contracts
Samples: www.sec.gov, Taubman Centers Inc
Excess Nonrecourse Liabilities. Pursuant to For purposes of determining a Partner's proportionate share of the "excess nonrecourse liabilities" of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), for the purpose of determining each such "excess nonrecourse liabilities" shall be allocated in accordance with such Partner’s 's share of excess Nonrecourse Liabilities of the PartnershipPartnership profits; provided, and solely for however, that each such purpose, each Partner’s interest in Partnership profits share shall be determined by any reasonable method chosen by the General PartnerPartner in its reasonable discretion under any method permitted under applicable Regulations.
Appears in 1 contract
Samples: Irt Property Co