Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), the Partners’ interests in Partnership profits are in proportion to their Percentage Interests.
Appears in 7 contracts
Samples: Limited Partnership Agreement (Cke Restaurants Inc), Limited Partnership Agreement (Aeroways, LLC), Limited Partnership Agreement (Verso Paper Corp.)
Excess Nonrecourse Liabilities. Solely for For purposes of determining a Partner’s 's proportionate share of the “"excess nonrecourse liabilities” " of the Partnership within the meaning of Treasury Regulations Section 1.752-3(a)(3), the Partners’ interests each Partner's interest in Partnership profits are in proportion shall be deemed to their be equal to such Partner's Percentage InterestsInterest.
Appears in 4 contracts
Samples: Agreement (Century Communications Corp), Management Agreement (Adelphia Communications Corp), Falcon Funding Corp
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s 's proportionate share of the “"excess nonrecourse liabilities” " of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), such "excess nonrecourse liabilities" first shall be allocated to those Partners who have, and in an amount equal to, such Partners' built-in gain under Regulations Section 1.704-3(a)(3)(ii) less any Nonrecourse Built-in Gain, and then shall be allocated among the Partners’ interests Partners in Partnership profits are in proportion to accordance with their respective Percentage Interests.
Appears in 4 contracts
Samples: Boddie Noell Properties Inc, Fac Realty Trust Inc, Fac Realty Inc
Excess Nonrecourse Liabilities. Solely for For purposes of determining a ------------------------------ Partner’s 's proportionate share of the “"excess nonrecourse liabilities” " of the Partnership within the meaning of Treasury Regulations Section 1.752-3(a)(3), the Partners’ interests each Partner's interest in Partnership profits are in proportion shall be deemed to their be equal to such Partner's Percentage InterestsInterest.
Appears in 3 contracts
Samples: Contribution and Formation Agreement (Insight Capital Inc), Insight Capital Inc, Insight Communications Co Inc
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s proportionate share of the “The "excess nonrecourse liabilities” " of the Partnership (within the meaning of Regulations Regulation Section 1.752-3(a)(3), ) shall be allocated among the Partners in accordance with the Partners’ interests in Partnership profits are in proportion to their ' Percentage Interests.
Appears in 2 contracts
Samples: Strategic Timber Trust Inc, Strategic Timber Trust Inc
Excess Nonrecourse Liabilities. Solely To the extent applicable, for purposes of determining a Partner’s proportionate share the allocation of the “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), ) to the Partners’ interests , each Partner’s interest in Partnership profits are shall be in proportion to their its Percentage InterestsInterest.
Appears in 2 contracts
Samples: Contribution Agreement (Thomas Properties Group Inc), Contribution Agreement (Thomas Properties Group Inc)
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of Treasury Regulations Section 1.7521 .752-3(a)(3), the Partners’ interests in Partnership profits are as follows: General Partner zero percent (0%) and Limited Partners one hundred percent (100%) (in proportion to their Percentage InterestsContributions).
Appears in 1 contract
Samples: Limited Partnership Agreement (Plymouth Opportunity REIT Inc.)
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of Treasury Regulations Section 1.752-3(a)(31.7523(a)(3), the Partners’ interests in Partnership profits are as follows: General Partner zero percent (0%) and Limited Partners one hundred percent (100%) (in proportion to their Percentage InterestsContributions).
Appears in 1 contract
Samples: Limited Partnership Agreement (Plymouth Opportunity REIT Inc.)
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), the Partners’ interests in Partnership profits are in proportion to their Percentage Intereststhe Partners’ economic interests in the Partnership.
Appears in 1 contract
Samples: Limited Partnership Agreement
Excess Nonrecourse Liabilities. Solely for For purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section U.S. Department of Treasury Reg. §1.752-3(a)(3), the Partners’ interests each Partner’s interest in Partnership profits are in proportion shall be proportionate to their such Partner’s relative Percentage InterestsInterest.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Industrial Property Trust Inc.)
Excess Nonrecourse Liabilities. Solely for purposes of ------------------------------ determining a Partner’s the Partners' proportionate share shares of the “"excess nonrecourse liabilities” " of the Partnership within the meaning of Regulations Section 1.752-1.752- 3(a)(3), the Partners’ ' interests in Partnership profits are Profits shall be in proportion to their Percentage InterestsUnits.
Appears in 1 contract
Excess Nonrecourse Liabilities. Solely for For purposes of determining a Partner’s proportionate share of the Partnership “excess nonrecourse liabilities” of the Partnership within the meaning of Treasury Regulations Section 1.752-3(a)(3), the Partners’ interests in shares of Partnership profits are shall be deemed to be in proportion to their pro rata share of the outstanding Percentage Interests.
Appears in 1 contract
Samples: Limited Partnership Agreement (HappyNest REIT, Inc.)
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s the Partners’ proportionate share shares of the “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), the Partners’ interests in Partnership profits are Profits shall be in proportion to their Percentage InterestsUnits.
Appears in 1 contract
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s The Partners’ proportionate share shares of the “excess nonrecourse liabilities” of the Partnership Partnership, within the meaning of Treasury Regulation 1.752-3(a)(3), shall be in accordance with a Partner’s Percentage Interest or any other method selected by the General Partner and permissible under the Regulations, including, but not limited to, the alternative method set forth in Regulations Section 1.752-3(a)(3), the Partners’ interests in Partnership profits are in proportion to their Percentage Interests.
Appears in 1 contract
Samples: Bluerock Homes Trust, Inc.
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), the Partners’ interests each Partner’s interest in Partnership profits are in proportion to their shall be such Partner’s Percentage InterestsInterest.
Appears in 1 contract
Samples: Limited Partnership Agreement (Commercial Net Lease Realty Inc)
Excess Nonrecourse Liabilities. Solely for purposes of determining a Partner’s proportionate share of the “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section 1.752-3(a)(3), the such “excess nonrecourse liabilities” first shall be allocated to those Partners who have, and in an amount equal to, such Partners’ interests built-in Partnership profits are gain under Regulations Section 1.704-3(a)(3)(ii) less any Nonrecourse Built-in proportion to Gain, and then shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Highwoods Properties Inc