Partner Nonrecourse Debt Minimum Gain. “Partner Nonrecourse Debt Minimum Gain” shall mean an amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if the Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Treasury Regulations Section 1.704-2(i)(3).
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Samples: Exempted Limited Partnership Agreement (GCM Grosvenor Inc.), Exempted Limited Partnership Agreement (GCM Grosvenor Inc.)
Partner Nonrecourse Debt Minimum Gain. “Partner Nonrecourse Debt Minimum Gain” shall mean an An amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if the such Partner Nonrecourse Debt were treated as a Nonrecourse Liabilitynonrecourse liability, determined in accordance with Treasury Regulations Section 1.704-2(i)(3)) of the Regulations.
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Samples: And Restated Agreement (Foundation Capital Resources Inc), Foundation Capital Resources Inc
Partner Nonrecourse Debt Minimum Gain. “Partner Nonrecourse Debt Minimum Gain” shall mean an amount, with With respect to each Partner Nonrecourse Debt, an amount equal to the Partnership Minimum Gain that would result if the such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Treasury Regulations Section 1.704-2(i)(3).
Appears in 2 contracts
Samples: Limited Partnership Agreement (Phillips Edison - ARC Shopping Center REIT Inc.), Limited Partnership Agreement (Phillips Edison - ARC Shopping Center REIT Inc.)
Partner Nonrecourse Debt Minimum Gain. “Partner Nonrecourse Debt Minimum Gain” shall mean means an amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if the such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Treasury Regulations Section Sections 1.704-2(i)(3)2(i) (2) and 1.704-2(i) (3) of the Treasury Regulations.
Appears in 1 contract
Samples: Operating Agreement (New Gaming Capital Partnership)
Partner Nonrecourse Debt Minimum Gain. “Partner Nonrecourse Debt Minimum Gain” shall mean an An amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if the such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Treasury Regulations Section 1.704-2(i)(3).2 (i) of the Regulations
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Partner Nonrecourse Debt Minimum Gain. “Partner Nonrecourse Debt Minimum Gain” shall mean means an amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if the such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Treasury the provisions of Regulations Section 1.704-2(i)(3)) relating to “partner nonrecourse debt minimum gain.”
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Partner Nonrecourse Debt Minimum Gain. “Partner Nonrecourse Debt Minimum Gain” shall mean an amount, with respect to each Partner Nonrecourse Debt, equal to the Partnership Minimum Gain that would result if the such Partner Nonrecourse Debt were treated as a Nonrecourse Liability, determined in accordance with Treasury the provisions of Regulations Section 1.704-2(i)(3)) relating to “partner nonrecourse debt minimum gain.”
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Samples: Penske Automotive Group, Inc.