Nonrecourse Liabilities. Nonrecourse Liabilities of the Partnership described in Treasury Regulation Section 1.752-3(a)(3) shall be allocated among the Partners in the manner chosen by the General Partner and consistent with such Treasury Regulation.
Appears in 28 contracts
Samples: Award Agreement (Och-Ziff Capital Management Group LLC), Award Agreement (Och-Ziff Capital Management Group LLC), Award Agreement (Och-Ziff Capital Management Group LLC)
Nonrecourse Liabilities. The portion of the Nonrecourse Liabilities of the Partnership described in that are allocable pursuant to Treasury Regulation Section 1.752-3(a)(3) shall be allocated among the Partners in the manner chosen accordance with their Percentage Interests. The allocations of Nonrecourse Liabilities that may be made as provided in Treasury Regulation Section 1.752-3(a)(2) are to be made as determined by the General Partner and consistent with such Treasury Regulationin its sole discretion.
Appears in 20 contracts
Samples: Securities Purchase Agreement (K-Sea Transportation Partners Lp), Operating Agreement (EnLink Midstream, LLC), Convertible Preferred Unit Purchase Agreement (EnLink Midstream Partners, LP)
Nonrecourse Liabilities. Nonrecourse Liabilities of the Partnership described in Treasury Regulation Section 1.752-3(a)(3) shall be allocated among the Partners in the manner chosen by the General Partner and consistent with such Treasury Regulation; provided that any Nonrecourse Liabilities of the Partnership outstanding as of the Recapitalization Date shall, nonetheless, be allocated among the Partners in accordance with the provisions of Treasury Regulation Section 1.752-3(a)(1) or (2).
Appears in 7 contracts
Samples: Letter Agreement (Och-Ziff Capital Management Group LLC), Governance Agreement (Och-Ziff Capital Management Group LLC), Agreement and Plan of Merger (Och-Ziff Capital Management Group LLC)
Nonrecourse Liabilities. Nonrecourse Liabilities of the Partnership described in U.S. Treasury Regulation Regulations Section 1.752-3(a)(3) shall be allocated among the Partners in the a manner chosen by the General Partner and consistent with such Treasury Regulation.
Appears in 7 contracts
Samples: Limited Partnership Agreement (Restaurant Brands International Inc.), Agreement and Plan of Merger (Broadcom Corp), Agreement (Broadcom Cayman L.P.)
Nonrecourse Liabilities. Nonrecourse Liabilities of the Partnership described in U.S. Treasury Regulation Regulations Section 1.752-3(a)(3) shall be allocated among the Partners in the a manner chosen by the General Partner and consistent with such U.S. Treasury RegulationRegulations.
Appears in 6 contracts
Samples: Limited Partnership Agreement (Telesat Corp), Limited Partnership Agreement (Telesat Partnership LP), Limited Partnership Agreement (Telesat Partnership LP)
Nonrecourse Liabilities. Nonrecourse Liabilities For purposes of the Partnership described in Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of Partnership (and all nonrecourse deductions within the meaning of Treasury Regulation Section 1.7042(b)(1)) shall be allocated among the Partners in the manner chosen by the General Partner and consistent with such Treasury Regulationto Nonaffiliated Partner.
Appears in 1 contract
Samples: Bj Services Co
Nonrecourse Liabilities. Nonrecourse Liabilities For purposes of the Partnership described in Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of Partnership (and all nonrecourse deductions within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Partners in the manner chosen by the General Partner and consistent with such Treasury Regulationto Nonaffiliated Partner.
Appears in 1 contract
Samples: Bj Services Co
