Debt Allocation. Indebtedness of the Partnership treated as “excess nonrecourse liabilities” (as defined in Treasury Regulations Section 1.752-3(a)(3)) shall be allocated among the Partners in the manner determined by the General Partner.
Appears in 8 contracts
Sources: Limited Partnership Agreement (TPG Inc.), Limited Partnership Agreement (TPG Gp A, LLC), Limited Partnership Agreement (TPG Inc.)
Debt Allocation. Indebtedness of the Partnership treated as “excess nonrecourse liabilities” (as defined in Treasury Regulations Regulation Section 1.752-3(a)(3)) shall be allocated among the Partners in based on their Percentage Interests; provided that the manner determined by Partnership may use an alternative method under the General applicable Treasury Regulations to allocate such excess nonrecourse liabilities if such method would not reasonably be expected to be adverse to any Partner.
Appears in 3 contracts
Sources: Limited Partnership Agreement (Galaxy Digital Inc.), Limited Partnership Agreement (Galaxy Digital Holdings Ltd.), Limited Partnership Agreement (Galaxy Digital Holdings Ltd.)
Debt Allocation. Indebtedness of the Partnership treated as “excess nonrecourse liabilities” (as defined in Treasury Regulations Regulation Section 1.752-3(a)(3)) shall be allocated among the Partners in the manner determined by the General Partnerbased on their Percentage Interests.
Appears in 1 contract
Sources: Limited Partnership Agreement (Rocket Companies, Inc.)
Debt Allocation. Indebtedness of the Partnership treated as “excess nonrecourse liabilities” (as defined in Treasury Regulations Regulation Section 1.752-3(a)(3)) shall be allocated among the Partners in the manner determined by discretion of the General Partner.
Appears in 1 contract
Sources: Limited Partnership Agreement (Rocket Companies, Inc.)