Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 139 contracts
Samples: Agreement, Exchange Agreement (Western Midstream Partners, LP), Partnership Interests Exchange Agreement (Western Midstream Partners, LP)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage InterestsPro Rata. If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 124 contracts
Samples: Management Services Agreement (Nextera Energy Partners, Lp), Exchange Agreement (Delek Logistics Partners, LP), Exchange Agreement (Delek US Holdings, Inc.)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 52 contracts
Samples: Agreement and Plan of Redemption and Merger (Markwest Hydrocarbon Inc), Agreement and Plan of Redemption and Merger (Markwest Energy Partners L P), Article Xiv Merger (Enterprise Products Operating L P)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 47 contracts
Samples: Signature (NGL Crude Terminals, LLC), Signature (Opr, LLC), Preferred Unit Purchase Agreement (Natural Resource Partners Lp)
Nonrecourse Deductions. Nonrecourse Deductions for any Partnership taxable period year shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does for such Partnership taxable year which would satisfy such requirements.
Appears in 41 contracts
Samples: Limited Partnership Agreement (Vinebrook Homes Trust, Inc.), Limited Partnership Agreement (Nexpoint Diversified Real Estate Trust), Limited Partnership Agreement (Vinebrook Homes Trust, Inc.)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 16 contracts
Samples: Agreement (Enterprise Products Partners L P), Enterprise Products Partners L P, Enterprise Products Partners L P
Nonrecourse Deductions. Nonrecourse Deductions for any Partnership taxable period year shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does for such Partnership taxable year which would satisfy such requirements.
Appears in 15 contracts
Samples: Gables Realty Limited Partnership, Gables Realty Limited Partnership, Agreement (Vinings Investment Properties Trust/Ga)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s 's Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 12 contracts
Samples: Unit Purchase Agreement (Cheniere Energy Partners, L.P.), Cheniere Energy Partners, L.P., Och Daniel
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 9 contracts
Samples: Contribution Agreement (Enbridge Energy Partners Lp), Contribution Agreement (Enbridge Energy Partners Lp), www.lw.com
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other PartnersLimited Partner, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 8 contracts
Samples: Contribution Agreement (Eott Energy Canada Lp), Contribution Agreement (Eott Energy Canada Lp), Ferrellgas Partners L P
Nonrecourse Deductions. Nonrecourse Deductions for any Partnership taxable period year shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Code Section 704(b) of the Code), the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does for such Partnership taxable year which would satisfy such requirements.
Appears in 8 contracts
Samples: Limited Partnership Agreement (Angel Oak Mortgage, Inc.), Pledge Agreement (NetSTREIT Corp.), Pledge Agreement (NetSTREIT Corp.)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.. 45
Appears in 8 contracts
Samples: Williams Partners L.P., Williams Partners L.P., Williams Partners L.P.
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 6 contracts
Samples: Original Agreement (Felcor Lodging Trust Inc), Article Xvi Merger (Enbridge Energy Partners Lp), Original Agreement (Felcor Lodging L P)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the Managing General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the Managing General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 6 contracts
Samples: Partnership Agreement (Crestwood Equity Partners LP), www.lw.com, Alliance Resource Partners Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 6 contracts
Samples: Agreement (Ferrellgas Partners Finance Corp), Agreement (Ferrellgas Partners Finance Corp), Agreement (Ferrellgas Partners Finance Corp)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other PartnersLimited Partner, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 5 contracts
Samples: Ferrellgas Partners Finance Corp, Reorganization Agreement (Enterprise Products Partners L P), Reorganization Agreement (Enterprise Products Partners L P)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable ---------------------- period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 5 contracts
Samples: Agreement (Cabot Industrial Properties Lp), Contribution Agreement (Cabot Industrial Trust), Agreement (Cabot Industrial Properties Lp)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 5 contracts
Samples: Agreement (Ferrellgas L P), Agreement, Agreement (Kinder Morgan Energy Partners L P)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the Managing General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the Managing General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 5 contracts
Samples: Cornerstone Propane Partners Lp, Cornerstone Propane Partners Lp, Alliance Resource Partners Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy satisfies such requirements.
Appears in 4 contracts
Samples: Star Group Lp, Star Gas Finance Co, Star Gas Partners Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the Managing General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the Managing General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 4 contracts
Samples: Partnership Agreement (Atlas Growth Partners, L.P.), CVR Energy Inc, CVR Energy Inc
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the Managing General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 4 contracts
Samples: Agreement and Plan of Merger (Inergy Holdings, L.P.), Agreement and Plan of Merger (Inergy L P), Inergy L P
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 4 contracts
Samples: Prologis, Mar Mar Realty Trust, Baron Capital Trust
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s 's Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 3 contracts
Samples: Management and Operation (Enterprise Products Partners L P), Enterprise Products Partners L P, Enterprise Products Partners L P
Nonrecourse Deductions. Nonrecourse Deductions for any taxable ---------------------- period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 3 contracts
Samples: Sunoco Logistics Partners Lp, Sunoco Logistics Partners Lp, Plains All American Pipeline Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Partnership Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 3 contracts
Samples: Copi Colorado Lp, Crescent Real Estate Equities Co, Crescent Real Estate Equities Co
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 3 contracts
Samples: Energy Transfer Operating, L.P., Energy Transfer Partners, L.P., media.corporate-ir.net
Nonrecourse Deductions. Nonrecourse Deductions for any Partnership taxable period year shall be allocated to the Partners in accordance with their respective Percentage InterestsGeneral Partner. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does for such Partnership taxable year which satisfy such requirements.
Appears in 3 contracts
Samples: Master Contribution Agreement (Pacific Gulf Properties Inc), Property Management Agreement (Pacific Gulf Properties Inc), Management Agreement (Pacific Gulf Properties Inc)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period year shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner Partnership determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section section 704(b) of the Code, the General Partner Partnership is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such the requirements.
Appears in 3 contracts
Samples: General Partnership Agreement, General Partnership Agreement (DCP Midstream Partners, LP), General Partnership Agreement (DCP Midstream Partners, LP)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 3 contracts
Samples: Kinder Morgan Management LLC, Kinder Morgan Energy Partners L P, Kinder Morgan Energy Partners L P
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other PartnersUnitholders, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 2 contracts
Samples: www.sec.gov, ONEOK Partners LP
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner Xxxxxx determines in good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Code Section 704(b) of the Code, ). the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Exterran Energy Solutions, L.P.), Limited Partnership Agreement (Exterran Energy Solutions, L.P.)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.requirements.
Appears in 2 contracts
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 2 contracts
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage InterestsInterests (calculated without regard to any Outstanding Series B Subordinated Units). If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 2 contracts
Samples: Agreement (Paa Natural Gas Storage Lp), Paa Natural Gas Storage Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage InterestsSharing Ratios. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 2 contracts
Samples: Original Agreement (Energy Transfer Equity, L.P.), Original Agreement (Energy Transfer Partners, L.P.)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Partnership Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 2 contracts
Samples: Crescent Real Estate Equities Co, Crescent Real Estate Equities Co
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Partnership Interests. If the General Partner determines determines, in its good faith discretion, that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury IRS Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.. (vi) Partner Nonrecourse Deductions. Partner Nonrecourse Deductions for any taxable period shall be allocated 100% to the Partner that bears the 8
Appears in 1 contract
Samples: Emeritus Corp\wa\
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Partnership Interests. If the General Partner determines determines, in its good faith discretion, that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Samples: Agree Realty Corp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Samples: Plum Creek Timber Co Inc
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period ---------------------- shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Code Section 704(b) of the Code), the General Partner is authorized, upon -------------- notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Limited Partnership Agreement (Hanover Compressor Co /)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Code Section 704(b) of the Code), the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: EES Leasing, LLC
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the U.S. Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, authorized to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Nonrecourse Deductions. Nonrecourse Deductions for any the taxable period shall be allocated to the Partners in accordance with their respective Percentage Interestsproportion to the number of OLP Common Units held. If the General Partner determines in good faith that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorizedmay, upon notice to the other Partners, to revise the prescribed ratio in order to the numerically closest ratio that does satisfy such safe harbor requirements.
Appears in 1 contract
Samples: Crosstex Energy Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable ----------------------- period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Penn Octane Corp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other PartnersLimited Partners in accordance with Section 4.4(e) hereof, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Samples: Security Capital Atlantic Inc
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period year shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Alliance Resource Partners Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other PartnersUnitholders, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: ONEOK Partners LP
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner Trustee determines that the Partnership’s 's Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner Trustee is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated in proportion to the Partners in accordance with their respective Percentage InterestsInterests of the Partners. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Samples: Hub Group Inc
Nonrecourse Deductions. Nonrecourse Deductions for any ---------------------- taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Plains All American Pipeline Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations Regulation promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Atlas Growth Partners, L.P.
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.requirements.
Appears in 1 contract
Samples: ir.energytransfer.com
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section Code section 704(b) of the Code), the General Partner is authorized, upon notice to the other PartnersLimited Partners in accordance with Section 4.4.5 hereof, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Samples: United Dominion Realty Trust Inc
Nonrecourse Deductions. Nonrecourse Deductions for any ----------------------- taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Penn Octane Corp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Code Section 704(b) of the Code), the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Limited Partnership Agreement (Hanover Compression Lp)
Nonrecourse Deductions. Nonrecourse Deductions for any the taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in good faith that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorizedmay, upon notice to the other Partners, to revise the prescribed ratio in order to the numerically closest ratio that does satisfy such safe harbor requirements.. The allocations in this portion of Section 6.1(d) are 50
Appears in 1 contract
Samples: Crosstex Energy Lp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in its good faith discretion that the Partnership’s Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Samples: Carramerica Realty Corp
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Partnership Interests. If the Managing General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the Managing General Partner is authorized, upon notice to the other Limited Partners, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the Managing General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Inergy L P
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines that the Partnership’s Nonrecourse Deductions should be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.. 57
Appears in 1 contract
Samples: Williams Pipeline Partners L.P.
Nonrecourse Deductions. Nonrecourse Deductions for any taxable ---------------------- period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the General Partner determines in good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Code Section 704(b) of the Code), the General Partner is authorized, upon -------------- notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Limited Partnership Agreement (Hanover Compressor Co /)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated to the Partners in accordance with their respective Percentage Interests. If the Operating General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the Operating General Partner is authorized, upon notice to the other Partners, to revise the prescribed ratio to the numerically closest ratio that does satisfy such requirements.
Appears in 1 contract
Samples: Agreement (Genesis Energy Lp)
Nonrecourse Deductions. Nonrecourse Deductions for any taxable period shall be allocated in proportion to the Partners in accordance with their respective Percentage InterestsInterests of the Partners. If the General Partner determines in its good faith discretion that the Partnership’s 's Nonrecourse Deductions should must be allocated in a different ratio to satisfy the safe harbor requirements of the Treasury Regulations promulgated under Section 704(b) of the Code, the General Partner is authorized, upon notice to the other PartnersLimited Partner, to revise the prescribed ratio to the numerically closest ratio that which does satisfy such requirements.
Appears in 1 contract
Samples: Hub Group Inc