Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 20 contracts
Samples: Operating Agreement, Limited Liability Company Agreement (Vanguard Natural Resources, LLC), Limited Liability Company Agreement (Vanguard Natural Resources, LLC)
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(33(a), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (Ai) the amount of Company Membership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Intereststhe manner determined by the Managing Member, provided that such allocation shall be permissible under Regulations Section 1.752-3.
Appears in 11 contracts
Samples: Limited Liability Company Agreement (Sunstone Hotel Investors, Inc.), Limited Liability Company Agreement (Sunstone Hotel Investors, Inc.), Limited Liability Company Agreement (Sunstone Hotel Investors, Inc.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective relative Percentage Interests.
Appears in 9 contracts
Samples: Limited Liability Company Agreement (SilverSun Technologies, Inc.), Limited Liability Company Agreement (SilverSun Technologies, Inc.), Limited Liability Company Agreement (Vine Energy Inc.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company Managing Member in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage InterestsPro Rata.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Viper Energy Partners LP), Limited Liability Company Agreement (First Solar, Inc.), Limited Liability Company Agreement (Sunpower Corp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage InterestsCommon Unitholders, Pro Rata.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Kimbell Royalty Partners, LP), Limited Liability Company Agreement (Kimbell Royalty Partners, LP), Limited Liability Company Agreement (Kimbell Royalty Partners, LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section Regulations § 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (Ai) the amount of Company Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage InterestsPro Rata.
Appears in 4 contracts
Samples: Operating Agreement (Sunoco LP), Operating Agreement (Energy Transfer Partners, L.P.), Support Agreement (Sunoco LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage InterestsSharing Ratios.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Enterprise Products Partners L P), Limited Liability Company Agreement (Enterprise Products Partners L P), Limited Liability Company Agreement (El Paso Corp/De)
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(33(a), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (Ai) the amount of Company Partnership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Intereststhe manner determined by the Managing Member, provided that such allocation shall be permissible under Regulations Section 1.752-3.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Morgans Hotel Group Co.), Limited Liability Company Agreement (Morgans Hotel Group Co.), Morgans Hotel Group Co.
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Eott Energy LLC), Limited Liability Company Agreement (Eott Energy Finance Corp), Limited Liability Company Agreement (Eott Energy LLC)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Membership Interests.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (El Paso Energy Partners Lp), Limited Liability Company Agreement (El Paso Energy Partners Lp), El Paso Energy Partners Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 3 contracts
Samples: Operating Agreement (U S Timberlands Klamath Falls LLC), Operating Agreement (U S Timberlands Klamath Falls LLC), Operating Agreement (U S Timberlands Co Lp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain (computed without duplication of items between (A) and (B)) shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Atlas Pipeline Holdings, L.P.), Limited Liability Company Agreement (Atlas Pipeline Partners Lp)
Nonrecourse Liabilities. For purposes of Treasury Regulation ----------------------- Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 2 contracts
Samples: Operating Agreement (U S Timberlands Co Lp), U S Timberlands Finance Corp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members ratably in accordance proportion with their respective Percentage Interestsshares of Nonrecourse Deductions.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Williams Partners L.P.), Purchase and Sale Agreement (Williams Partners L.P.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage InterestsPro Rata.
Appears in 2 contracts
Samples: Operating Agreement (Niska Gas Storage Partners LLC), Operating Agreement (Niska Gas Storage Partners LLC)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall will be allocated among the Members to each Member in accordance with their its respective Percentage InterestsSharing Ratio.
Appears in 2 contracts
Samples: Acknowledgment and Acceptance Agreement (El Paso Corp/De), Acknowledgment and Acceptance Agreement (Enterprise Products Partners L P)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-Built in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 2 contracts
Samples: Limited Liability Company (Williams Partners L.P.), Limited Liability Company Agreement (ONEOK Partners LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interestsrelative Contribution Percentages.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Inergy Storage, Inc.), Limited Liability Company Agreement (Crestwood Midstream Partners LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company Managing Member in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage InterestsPro Rata.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Rattler Midstream Lp), Limited Liability Company Agreement (Rattler Midstream Lp)
Nonrecourse Liabilities. For the purposes of Treasury Regulation Section Regulations section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among between the Members in accordance with their respective Percentage Interests.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (DCP Midstream Partners, LP), Limited Liability Company Agreement (DCP Midstream Partners, LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section Regulations § 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (Ai) the amount of Company Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Equity Percentage Interests.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Paulsboro Natural Gas Pipeline Co LLC)
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(33(a), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (Ai) the amount of Company Partnership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated pro rata among the Members in accordance with their respective Percentage InterestsUnits, provided that such allocation shall be permissible under Regulations Section 1.752-3.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Morgans Hotel Group Co.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Regency Energy Partners LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members Member in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Atlas Energy Group, LLC)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in 36 42 Gain shall be allocated among the Members in accordance with their respective Percentage Membership Interests.
Appears in 1 contract
Samples: Limited Liability Company Agreement (El Paso Energy Partners Lp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Williams Partners L.P.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Company Agreement (Enterprise Products Partners L P)
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(33(a), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (Ai) the amount of Company Partnership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated pro rata among the Members in accordance with their respective Percentage InterestsMembership Units, provided that such allocation shall be permissible under Regulations Section 1.752-3.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Morgans Hotel Group Co.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage InterestsMembers, Pro Rata.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Linn Energy, LLC)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.and
Appears in 1 contract
Samples: Limited Liability Company Agreement
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(31.752 -3(a)(3), the Members agree that Nonrecourse Liabilities of the Company in excess of the sum of (A) the amount of Company Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Members in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Operating Agreement (U S Timberlands Klamath Falls LLC)
