Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 291 contracts
Samples: Partnership Agreement (Crestwood Equity Partners LP), Energy Transfer LP, Agreement
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsPro Rata.
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 Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among as determined by the Partners General Partner in accordance with their respective Percentage Interestsany permissible method under Treasury Regulation Section 1.752-3(a)(3).
Appears in 26 contracts
Samples: Agreement, Assignment and Assumption Agreement (USD Partners LP), Exchange Agreement (CNX Resources Corp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsPartners, Pro Rata.
Appears in 16 contracts
Samples: Partnership Agreement (CVR Refining, LP), CVR Partners, Lp, Kimbell Royalty Partners, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners General Partner and the holders of Common Units in accordance with their respective Percentage Intereststhe allocation of Net Income set forth in Section 5.1(a)(ii).
Appears in 11 contracts
Samples: Contribution Agreement (Enbridge Energy Partners Lp), Contribution Agreement (Enbridge Energy Partners Lp), www.lw.com
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among with and under any method approved by the Partners in accordance with their respective Percentage Interestsapplicable Treasury Regulations promulgated under Section 752 of the Code as chosen by the General Partner.
Appears in 9 contracts
Samples: Fourth (Summit Midstream Partners, LP), Agreement and Plan of Merger (Andeavor Logistics Lp), Agreement and Plan of Merger (Andeavor)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 9 contracts
Samples: Agreement (Enterprise Products Partners L P), Enterprise Products Partners L P, Williams Randa Duncan
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31.752‑3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 8 contracts
Samples: Management and Operation (Enterprise Products Partners L P), www.sec.gov, Enterprise Products Partners L P
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among as determined by the Partners General Partner in accordance with their respective Percentage Interestsany method permitted under Treasury Regulation Section 1.752-3(a)(3).
Appears in 7 contracts
Samples: Landmark Infrastructure Partners LP, Armada Enterprises Lp, Landmark Infrastructure Partners LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsPro Rata.
Appears in 5 contracts
Samples: Mach Natural Resources Lp, Mach Natural Resources Lp, TXO Energy Partners, L.P.
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section ----------------------- 1.752-3(a)(33(a), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (Ai) the amount of Partnership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 5 contracts
Samples: Contribution Agreement (Cabot Industrial Trust), Agreement (Cabot Industrial Properties Lp), Agreement (Cabot Industrial Properties Lp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31.752‑3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsPro Rata.
Appears in 5 contracts
Samples: Agreement (Williams Partners L.P.), Agreement (Williams Partners L.P.), Agreement (Williams Partners L.P.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interestspro rata.
Appears in 4 contracts
Samples: Amended and Restated Agreement (Harbinger Group Inc.), Agreement (Exco Resources Inc), Agreement (Harbinger Group Inc.)
Nonrecourse Liabilities. For purposes of Treasury Regulation ----------------------- Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 4 contracts
Samples: Plains All American Pipeline Lp, Plains All American Pipeline Lp, Sunoco Logistics Partners Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interestsand under any method approved by the applicable regulations under Section 752 of the Code as chosen by the General Partner.
Appears in 4 contracts
Samples: Sharing Agreement (Phillips 66 Partners Lp), Partnership Interests Restructuring Agreement (Phillips 66), Sharing Agreement (Phillips 66 Partners Lp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(33(a), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (Ai) the amount of Partnership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 4 contracts
Samples: Baron Capital Trust, Security Capital Atlantic Inc, Baron Capital Trust
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsCommon Unitholders, Pro Rata.
Appears in 4 contracts
Samples: www.sec.gov, Kimbell Royalty Partners, LP, Black Stone Minerals, L.P.
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-1.752- 3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 4 contracts
Samples: Contribution Agreement (Atlas Pipeline Partners Lp), Contribution Agreement (Resource America Inc), Atlas Pipeline Partners Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 3 contracts
Samples: www.sec.gov, Dorchester Minerals Lp, Combination Agreement (Dorchester Minerals Lp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-1.752 3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 3 contracts
Samples: Enterprise GP Holdings L.P., Enterprise GP Holdings L.P., Enterprise GP Holdings L.P.
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (BA) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 3 contracts
Samples: Preferred Unit Purchase Agreement (Natural Resource Partners Lp), Preferred Unit Purchase Agreement, Agreement
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners 49.49% to the General Partner and 50.51% to all Limited Partners in accordance with their the proportion that the respective Percentage Interestsnumber of Units held by them bears to the total number of Units then outstanding.
Appears in 3 contracts
Samples: El Paso Corp/De, El Paso Energy Partners Lp, Gulfterra Energy Partners L P
Nonrecourse Liabilities. For the purposes of Treasury Regulation Section Regulations section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 3 contracts
Samples: General Partnership Agreement, General Partnership Agreement (DCP Midstream Partners, LP), General Partnership Agreement (DCP Midstream Partners, LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners Unitholders as determined by the General Partner in accordance with their respective Percentage Interestsany method as permitted under Treasury Regulation Section 1.752-3(a)(3).
Appears in 2 contracts
Samples: www.lw.com, PennTex Midstream Partners, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.;
Appears in 2 contracts
Samples: Kaneb Pipe Line Partners L P, Kaneb Pipe Line Partners L P
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 2 contracts
Samples: Agreement, Agreement (Kinder Morgan Energy Partners L P)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsInterests (calculated without regard to any Outstanding Series B Subordinated Units).
Appears in 2 contracts
Samples: Agreement (Paa Natural Gas Storage Lp), Paa Natural Gas Storage Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsSharing Ratios.
Appears in 2 contracts
Samples: Original Agreement (Energy Transfer Equity, L.P.), Original Agreement (Energy Transfer Partners, L.P.)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsUnitholders Pro Rata.
Appears in 2 contracts
Samples: World Point Terminals, LP, World Point Terminals, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Regulations Section 1.752-3(a)(33(a), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (Ai) the amount of Partnership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with proportion to their respective Percentage Interests.
Appears in 2 contracts
Samples: Hub Group Inc, Hub Group Inc
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners General Partner and the holders of Common Units and Class B Units in accordance with their respective Percentage Intereststhe allocation of Net Income set forth in Section 5.1(a)(iii).
Appears in 2 contracts
Samples: Kinder Morgan Energy Partners L P, Kinder Morgan Energy Partners L P
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 2 contracts
Samples: American Energy Capital Partners - Energy Recovery Program, Lp, American Energy Capital Partners, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31.752‑3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Built‑in Gain shall be allocated among with and under any method approved by the Partners in accordance with their respective Percentage Interestsapplicable Treasury Regulations promulgated under Section 752 of the Code as chosen by the General Partner.
Appears in 1 contract
Samples: Summit Midstream Partners, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.Pro Rata. PBF Logistics LP Third Amended and Restated Agreement of Limited Partnership WAS:215692.2
Appears in 1 contract
Samples: PBF Logistics LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of 34 Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Buckeye GP Holdings L.P.
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(33 (a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Spectra Energy Partners, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Limited Partners in accordance with their respective Percentage InterestsPro Rata.
Appears in 1 contract
Samples: Memorial Production Partners LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-1.752 3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Genesis Energy Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31.752‑3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership Company in excess of the sum of (Ai) the amount of Partnership Minimum Gain and (Bii) the total amount of Nonrecourse Built-in Gain shall will be allocated among the Partners Parties in accordance with their respective Percentage Partnership Interests.
Appears in 1 contract
Samples: Performance Guaranty Agreement (Teppco Partners Lp)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Plains Marketing, L.P. Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Plains All American Pipeline Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31.752‑3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in 52 Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among as determined by the Partners General Partner in accordance with their respective Percentage Interestsany permissible method under Treasury Regulation Section 1.752-3 (a)(3).
Appears in 1 contract
Samples: www.lw.com
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.Pro Rata. WESTERN REFINING LOGISTICS, LP SECOND AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Samples: Western Refining Logistics, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-1.752 3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-Built in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Ferrellgas Finance Corp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.Pro Rata. QR Energy, LP First Amended and Restated Agreement of Limited Partnership
Appears in 1 contract
Samples: QR Energy, LP
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.. (ix) CODE
Appears in 1 contract
Samples: Cornerstone Propane Partners Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-Built in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Agreement (Ferrellgas L P)
Nonrecourse Liabilities. For purposes of Treasury ------------------------ Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Penn Octane Corp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.Pro Rata. ALON USA PARTNERS, LP FIRST AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Samples: Agreement (Alon USA Partners, LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.Pro Rata. WESTERN REFINING LOGISTICS, LP FIRST AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31T(e)(ii)(C), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.;
Appears in 1 contract
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31.752‑3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-Built in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Ferrellgas Partners Finance Corp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsUnitholders Pro Rata or as otherwise determined by the General Partner using such method as permitted under Treasury Regulation Section 1.752-3(a)(3).
Appears in 1 contract
Samples: Cypress Energy Partners, L.P.
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-Built- in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Genesis Energy Lp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (Aa) the amount of Partnership Minimum Gain and (Ba) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage InterestsPro Rata.
Appears in 1 contract
Samples: Inergy Midstream, L.P.
Nonrecourse Liabilities. For purposes of Treasury Regulation Section ------------------------ 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Penn Octane Corp
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(31T(e)(ii)(C), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: Lakehead Pipe Line Partners L P
Nonrecourse Liabilities. For purposes of Treasury Regulation Section section 1.752-3(a)(33(a), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (Aa) the amount of Partnership Minimum Gain and (Bb) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Samples: United Dominion Realty Trust Inc
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.. C:\My Documents\Mlpagt.wpd EXECUTION COPY 22
Appears in 1 contract
Samples: Enterprise Products Partners L P
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.Pro Rata. PBF LOGISTICS LP FIRST AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Samples: Agreement (PBF Logistics LP)
Nonrecourse Liabilities. For purposes of Treasury Regulation Section 1.752-3(a)(3), the Partners agree that Nonrecourse Liabilities of the Partnership in excess of the sum of (A) the amount of Partnership Minimum Gain and (B) the total amount of Nonrecourse Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.. 35
Appears in 1 contract
Samples: Alliance Resource Partners Lp
