Excess Nonrecourse Liabilities. The Partnership shall allocate “nonrecourse liabilities” (within the meaning of Regulations Section 1.752-1(a)(2)) of the Partnership that are secured by multiple properties under any reasonable method chosen by the General Partner in accordance with Regulations Section 1.752-3(b). The Partnership shall allocate “excess nonrecourse liabilities” of the Partnership within the meaning of Regulations Section 1.752-3(a)(3) first to the Special Limited Partner up to the amount of the Special Limited Partner’s share of built-in gains that is allocable to Code Section 704(c) property or property for which reverse Code Section 704(c) allocations are applicable, and second under any method chosen by the General Partner in its sole discretion that is permitted under Regulations Section 1.752-3(a)(3).
Appears in 9 contracts
Samples: Limited Partnership Agreement (IPC Alternative Real Estate Income Trust, Inc.), Limited Partnership Agreement (EQT Exeter Real Estate Income Trust, Inc.), Limited Partnership Agreement (IPC Alternative Real Estate Income Trust, Inc.)
