Allocation of Nonrecourse Liabilities. For purposes of determining each Partner’s share of Nonrecourse Liabilities, if any, of the Partnership in accordance with Treasury Regulations Section 1.752-3(a)(3), the Partners’ interest in Partnership profits shall be determined in the same manner as prescribed by Section 4.4.5.
Allocation of Nonrecourse Liabilities. For purposes of determining each Member’s share of Nonrecourse Liabilities, if any, of the Company in accordance with Regulations Section 1.752-3(a)(3), the Members’ interests in Company profits shall be determined in the same manner as prescribed by Section 6.03(e).
Allocation of Nonrecourse Liabilities. The “excess nonrecourse liabilities” of the Company (within the meaning of Section 1.752-3(a)(3) of the Regulations) shall be shared by the Members in accordance with their respective Ownership Percentages.
Allocation of Nonrecourse Liabilities. A Member’s share of the nonrecourse liabilities of the Company shall be allocated in accordance with Treasury Regulation §1.752-3(a), except that excess nonrecourse liabilities shall be allocated among the members in accordance with the manner in which the Members reasonably expect that the nonrecourse deductions allocable to such liabilities will be allocated.
Allocation of Nonrecourse Liabilities. The "excess nonrecourse liabilities" of the Partnership (within the meaning of Section 1.752-3(a)(3) of the Regulations) shall be allocated to the Partners in accordance with their respective Residual Percentages.
Allocation of Nonrecourse Liabilities. For purposes of determining a Holder’s proportional share of the “excess nonrecourse liabilities” of the Company within the meaning of Regulations Section 1.752-3(a)(3), each Holder’s respective interest in Company profits shall be equal to such Holder’s Percentage Interest with respect to Membership Common Units.
Allocation of Nonrecourse Liabilities. The "excess nonrecourse ------------------------------------- liabilities" of the Partnership (as defined in Regulations Section 1.752- 3(a)(3)) shall be allocated among the Partners in proportion to their respective interests in Common Partnership Units.
Allocation of Nonrecourse Liabilities. The Partners’ shares of Nonrecourse Liabilities shall be determined in accordance with rules of Treasury Regulations Section 1.752-3. “Excess nonrecourse liabilities” (as that term is defined in Treasury Regulations Section 1.752-3(a)(3)) shall be allocated among the Partners in accordance with their respective Partner Percentages.
Allocation of Nonrecourse Liabilities. For purposes of Regulation Section 1.752-3(a)(3), “excess nonrecourse liabilities” (other than any indebtedness for borrowed money that is both (i) not in existence immediately prior to the time of the IPO, and (ii) is not a refinancing or a successive refinancing of any indebtedness for borrowed money in existence immediately prior to the time of the IPO) shall be allocated to Parent in an amount equal to Parent’s Section 704(c) gain (to the extent not captured pursuant to Regulation Section 1.752-3(a)(1) and (2)). For this purpose, “indebtedness for borrowed money” does not include trade payables or other operating liabilities.
Allocation of Nonrecourse Liabilities. The “excess nonrecourse liabilities” of the Company (within the meaning of Section 1.752-3(a)(3) of the Regulations) shall be allocated as prescribed by the Regulations.
