Specified Partnership definition

Specified Partnership means (i) any Subsidiary of the Company and (ii) any entity other than a Subsidiary of the Company in which the Company or any of its Subsidiaries owns an interest, in each case that is treated as a partnership for U.S. federal income Tax purposes.
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Specified Partnership means a limited partnership for which HPS GP, LLC or one of its affiliates is the sole general partner, for which the Borrower and one or more of other funds managed or advised by the Collateral Manager or its Affiliates are the sole limited partners, and that is formed for the principal purpose of holding one or more Collateral Loans.
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Examples of Specified Partnership in a sentence

  • Upon any such contribution of an Excluded Property or the proceeds therefrom, the Special Limited Partner shall receive in exchange for such contribution, notwithstanding the actual value of such Excluded Property or the amount of such proceeds (as the case may be), the Specified Partnership Units applicable to such Excluded Property.

  • The Partnership is expressly authorized to issue the Specified Partnership Units in the numbers specified in this Section 4.9 without any further act, approval or vote of any Partner or any other Persons.

  • Definition of Specified Partnership Business Limit and Assignment Under Subsection 125(8)The definition of SPBL is contained in subsection 125(7), and it is analogous to the pro rata $500,000 limit in the old SPI definition.

  • The letter opinion included6 many of the above factual recitations, as well as specific findings relating to a constructive trust and a7 partnership accounting.8 Defendant filed his Chapter 7 petition on March 23, 2015.

  • Please note that even if a Specified Partnership has an obligation of prior filing, it may use the exemption it the relevant requirements are met.

  • Click to edit Master title style Ι• Go to http://datawarehouse.hrs a.gov/tools/analyzers/hps afind.aspx to begin searching for a HPSA designations • Select the state Click the down arrow for State search • Select County • Then, choose a discipline.

  • Both methods are performing very well once again, and the impor- tant observation is that the absolute error remains in the order of 10−3, although the dimension of the problem FIGURE 4.6. Basket option prices (top right), differences between price and payoff (bottom right) and differences between the proposed method and quasi Monte Carlo (left), using the implicit-explicit Euler scheme and an ANN for the calculation of the integral, for d = 15.

  • Special Rule for Specified Partnership LoansThe Treasury Department and the IRS are aware that certain loans made to a partnership by a United States person, or a member of its affiliated group, that owns an interest (directly or indirectly) in the partnership can result in a distortion in the determination of theforeign tax credit limitation under section 904 when the same person takes into account both a distributive share of the interest expense and the interest income with respect to the same loan.

  • Proposed subsections 125(3.2) and 125(8) will permit assignments to be made to transfer access to the SBD between corporations receiving SCI or Specified Partnership Income (SPI).

  • The Specified Partnership Value may be a positive or negative amount.

Related to Specified Partnership

  • Disqualified Partnership Any domestic entity classified as a partnership under the Code if any of its direct or indirect beneficial owners (other than through a U.S. corporation) are (or, under the applicable partnership agreement, are permitted to be) Disqualified Non-United States Tax Persons.

  • Section 385 Controlled Partnership has the meaning set forth in Treasury Regulation Section 1.385-1(c)(1) for a “controlled partnership”.

  • General partnership means an organization formed under chapters 45-13 through 45-21.

  • Operating Partnership has the meaning set forth in the preamble.

  • Public-private partnership means an arrangement or agreement, occurring on or after January 1, 2017, between a procurement unit and one or more contractors to provide for a public need through the development or operation of a project in which the contractor or

  • General Partnership Interest means a Partnership Interest held by the General Partner that is a general partnership interest.

  • Surviving Partnership has the meaning set forth in Section 11.2.B(ii) hereof.

  • Limited Partnership Interest means the ownership interest of a Limited Partner in the Partnership at any particular time, including the right of such Limited Partner to any and all benefits to which such Limited Partner may be entitled as provided in this Agreement and in the Act, together with the obligations of such Limited Partner to comply with all the provisions of this Agreement and of the Act.

  • Foreign limited partnership means a partnership formed under laws other than of this state and having as partners one or more general partners and one or more limited partners.

  • Co-licensed partner means a person who, with at least one other person, has the right to engage in

  • Initial Limited Partners means the Organizational Limited Partner (with respect to the Common Units and Subordinated Units received by it as described in Section 5.1), the General Partner (with respect to the Incentive Distribution Rights received by it as described in Section 5.1) and the Underwriters, in each case upon being admitted to the Partnership in accordance with Section 10.1.

  • GP means Gottbetter & Partners, LLP.

  • Selling Partner has the meaning set forth in Section 8.5.

  • Partnership Subsidiary means Host LP and any partnership, limited liability company, or other entity treated as a partnership for federal income tax purposes or disregarded as a separate entity for federal income tax purposes in which either Host REIT or Host LP owns (or owned on or after January 1, 1999) an interest, either directly or through one or more other partnerships, limited liability companies or other entities treated as a partnership for federal income tax purposes or disregarded as a separate entity for federal income tax purposes (whether or not Host REIT or Host LP has a controlling interest in, or otherwise has the ability to control or direct the operation of, such entity). Notwithstanding the foregoing, the term “Partnership Subsidiary” shall not in any way be deemed to include the Non-Controlled Subsidiaries or subsidiaries thereof, the Taxable REIT Subsidiaries or subsidiaries thereof, or the Subsidiary REITs or subsidiaries thereof.

  • Limited liability partnership or “LLP” shall mean a Company governed by Limited Liability Partnership Act 2008 or as amended;

  • Partnership has the meaning set forth in the Preamble.

  • Limited partnership means a limited partnership registered or formed under any law in force in Singapore or elsewhere;

  • Partnership Percentage means the percentage share of each Partner in the Net Income or Net Loss of the Partnership. The Partners’ initial Partnership Percentages shall be proportionate to the Partners’ initial Capital Contributions to the Partnership. Thereafter, subject to Section 1.68(g), such Partnership Percentages shall be adjusted only to reflect a disproportionate Capital Contribution by one or more Partners or a disproportionate distribution to one or more Partners, with disproportion being determined in accordance with Sections 4.2(a) and 4.5(b), except as set forth in Section 1.68(f).

  • REIT means a real estate investment trust under Sections 856 through 860 of the Code.

  • Departing Partner means a former General Partner from and after the effective date of any withdrawal or removal of such former General Partner pursuant to Section 11.1 or 11.2.

  • Deemed Partnership Interest Value means, as of any date with respect to any class of Partnership Interests, the Deemed Value of the Partnership Interests of such class multiplied by the applicable Partner's Percentage Interest of such class.

  • Initial Limited Partner has the meaning set forth in the Preamble.

  • Investor Limited Partner means any Limited Partner so designated at the time of its admission as a partner of the Partnership.

  • LP means the aggregate quantity of Lost Production during such Month (expressed in MWh) and

  • MLP Partnership Agreement means the Amended and Restated Agreement of Limited Partnership of the MLP, as amended or restated from time to time.

  • General Partner means the general partner of the Partnership.