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 295 contracts
Sources: Limited Partnership Agreement (Sunoco LP), Limited Partnership Agreement (Energy Transfer LP), Limited Partnership Agreement (Energy Transfer 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 InterestsPro Rata.
Appears in 127 contracts
Sources: Limited Partnership Agreement (XPLR Infrastructure, LP), Limited Partnership Agreement (Delek Logistics Partners, LP), Limited Partnership Agreement (Nextera 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 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
Sources: Limited Partnership Agreement (USD Partners LP), Contribution, Conveyance and Assumption Agreement (USD Partners LP), Limited Partnership 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 InterestsPartners, Pro Rata.
Appears in 16 contracts
Sources: Limited Partnership Agreement (CVR Refining, LP), Limited Partnership Agreement (CVR Partners, Lp), Limited Partnership Agreement (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 Pro Rata; provided, however, that pursuant to Temporary Treasury Regulation Section 1.707-5T(a)(2)(i), liabilities shall be allocated for the purposes of Treasury Regulation Section 1.707-5 in accordance with their respective Percentage Intereststhe Partners’ interests in the Partnership’s profits, as determined by the General Partner.
Appears in 14 contracts
Sources: Agreement of Limited Partnership (MPLX Lp), Agreement of Limited Partnership (MPLX Lp), Limited Partnership Agreement (MPLX 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
Sources: Agreement of Limited Partnership (Enbridge Energy Partners Lp), Limited Partnership Agreement, Limited Partnership 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 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
Sources: Limited Partnership Agreement (Summit Midstream Partners, LP), Agreement of Limited Partnership (Andeavor Logistics Lp), Limited Partnership Agreement (Andeavor 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.
Appears in 9 contracts
Sources: Limited Partnership Agreement (Enterprise Products Partners L P), Limited Partnership Agreement (Enterprise Products Partners L P), Limited Partnership Agreement (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
Sources: Limited Partnership Agreement, Limited Partnership Agreement (Enterprise Products Partners L P), Limited Partnership Agreement (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
Sources: Agreement of Limited Partnership (Landmark Infrastructure Partners LP), Limited Partnership Agreement (Armada Enterprises Lp), Agreement of Limited Partnership (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
Sources: Limited Partnership Agreement (Mach Natural Resources Lp), Agreement of Limited Partnership (Mach Natural Resources Lp), Agreement of Limited Partnership (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
Sources: Limited Partnership Agreement (Cabot Industrial Properties Lp), Limited Partnership Agreement (Cabot Industrial Trust), Contribution Agreement (Cabot Industrial Trust)
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
Sources: Limited Partnership Agreement (Williams Partners L.P.), Limited Partnership Agreement (Williams Partners L.P.), Limited Partnership 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 Interests.
Appears in 4 contracts
Sources: Limited Partnership Agreement (Plains All American Pipeline Lp), Limited Partnership Agreement (Sunoco Logistics Partners Lp), Agreement of Limited Partnership (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 InterestsCommon Unitholders, Pro Rata.
Appears in 4 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement (Kimbell Royalty Partners, LP), Limited Partnership Agreement (Black Stone Minerals, 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 4 contracts
Sources: Limited Partnership Agreement (Baron Capital Trust), Limited Partnership Agreement (Baron Capital Trust), Limited Partnership Agreement (Security Capital Atlantic Inc)
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
Sources: Agreement of Limited Partnership (Alliance Resource Partners Lp), Contribution Agreement (Atlas Pipeline Partners Lp), Contribution Agreement (Resource America 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 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
Sources: Limited Partnership Agreement (Phillips 66 Partners Lp), Partnership Interests Restructuring Agreement (Phillips 66), Limited Partnership Agreement (Phillips 66 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 Interestspro rata.
Appears in 4 contracts
Sources: Agreement of Limited Partnership (Harbinger Group Inc.), Limited Partnership Agreement (Harbinger Group Inc.), Limited Partnership Agreement (Exco Resources 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 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
Sources: Limited Partnership Agreement (Gulfterra Energy Partners L P), Limited Partnership Agreement (El Paso Corp/De), Limited Partnership Agreement (El Paso Energy 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 3 contracts
Sources: Limited Partnership Agreement (Enterprise GP Holdings L.P.), Limited Partnership Agreement (Enterprise GP Holdings L.P.), Limited Partnership Agreement (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 (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
Sources: Agreement of Limited Partnership, Limited Partnership Agreement (Dorchester Minerals Lp), Combination Agreement (Dorchester Minerals Lp)
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
Sources: 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 (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
Sources: Limited Partnership Agreement (Natural Resource Partners Lp), Limited Partnership Agreement, Limited Partnership 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 InterestsUnitholders Pro Rata.
Appears in 2 contracts
Sources: Limited Partnership Agreement (World Point Terminals, LP), Limited Partnership Agreement (World Point Terminals, 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 shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 2 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement (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
Sources: Limited Partnership Agreement (American Energy Capital Partners - Energy Recovery Program, Lp), Agreement of Limited Partnership (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 Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 2 contracts
Sources: Limited Partnership Agreement (Westmoreland Resource Partners, LP), Contribution Agreement (WESTMORELAND COAL Co)
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
Sources: Limited Partnership Agreement (Paa Natural Gas Storage Lp), Limited Partnership Agreement (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 Interests.;
Appears in 2 contracts
Sources: Limited Partnership Agreement (Kaneb Pipe Line Partners L P), Limited Partnership Agreement (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 in accordance with their respective Percentage InterestsSharing Ratios.
Appears in 2 contracts
Sources: Limited Partnership Agreement (Energy Transfer Equity, L.P.), Agreement of Limited Partnership (Energy Transfer 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 proportion to their respective Percentage Interests.
Appears in 2 contracts
Sources: Agreement of Limited Partnership (Hub Group Inc), Partnership Agreement (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 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
Sources: Limited Partnership Agreement, Limited Partnership Agreement (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 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
Sources: Limited Partnership Agreement (Kinder Morgan Energy Partners L P), Limited Partnership 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 Interests.Pro Rata. QR Energy, 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)(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
Sources: Limited Partnership Agreement (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 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
Sources: Limited Partnership 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 Interests.Pro Rata. WESTERN REFINING LOGISTICS, LP SECOND AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Sources: Limited Partnership Agreement (Western Refining 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.. C:\My Documents\Mlpagt.wpd EXECUTION COPY 22
Appears in 1 contract
Sources: Limited Partnership Agreement (Enterprise Products Partners 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 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 the Limited Partners in accordance with their respective Percentage InterestsPro Rata.
Appears in 1 contract
Sources: Limited Partnership Agreement (Memorial Production Partners LP)
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
Sources: Limited Partnership Agreement (United Dominion Realty Trust Inc)
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
Sources: Agreement of Limited Partnership (Summit Midstream Partners, LP)
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
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
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. WAS:215692.2
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
Sources: Limited Partnership Agreement (Kaneb Pipe Line Operating Partnership Lp)
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
Sources: Limited Partnership Agreement (Lakehead 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-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)(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
Sources: Limited Partnership Agreement (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.Pro Rata. PBF 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)(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
Sources: Limited Partnership Agreement (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-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
Sources: Limited Partnership 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 Plains Marketing, L.P. Built-in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Sources: Agreement of Limited Partnership (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-Built in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Sources: Limited Partnership Agreement (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 Interests.Pro Rata. WESTERN REFINING LOGISTICS, LP FIRST AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
Sources: Limited Partnership Agreement (Western Refining 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.. (ix) CODE
Appears in 1 contract
Sources: Limited Partnership Agreement (Cornerstone Propane 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-Built in Gain shall be allocated among the Partners in accordance with their respective Percentage Interests.
Appears in 1 contract
Sources: Limited Partnership Agreement (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.. 35
Appears in 1 contract
Sources: Limited Partnership Agreement (Alliance Resource 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