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.S. federal income tax purposes, the Fiscal Year shall end on such date. "FOIA" shall have the meaning ascribed to such term in Section 14.10(c). "FOIA Limited Partner" shall have the meaning ascribed to such term in Section 14.10(b). "Fund" has the meaning provided in the preamble. "Fund Expenses" means,
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00803533 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section I .752-I(aX2
.S. federal income tax purposes, the Fiscal Year shall end on such date. "FOIA" shall have the meaning ascribed to such term in Section 14.10(c). "FOIA Limited Partner" shall have the meaning ascribed to such term in Section 14.10(b). "Fund" has the meaning provided in the preamble. "Fund Expenses" means,
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614677 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section I .752-I(aX2
.S. federal income tax purposes, the Fiscal Year shall end on such date. "FOIA" shall have the meaning ascribed to such term in Section 14.10(c). "FOIA Limited Partner" shall have the meaning ascribed to such term in Section 14.10(b). "Fund" has the meaning provided in the preamble. "Fund Expenses" means,
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614635 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section 1.752-1(aX2)
Entities connected to both FOIA Limited and the Partnership Minimum Gain
Classes of Interests: Side Letters
ORGANIZATION
Samantha Power
PERSONthe New York Stock Exchange
ORGANIZATION
FedEx
ORGANIZATION
Dover
LOCATION
the Cayman Islands
LOCATIONLimited Partner Interests
ORGANIZATION
New York
LOCATIONthe Southern District
LOCATION
United States District Court
ORGANIZATIONHoneycomb Asset Management LP
ORGANIZATIONClasses of Interests
ORGANIZATIONthe Initial Closing
ORGANIZATIONSection 7.01 Management
ORGANIZATIONSection 9.03 Information on Investment
ORGANIZATIONSection 9.06 Limited Partners'
ORGANIZATIONOutside Activities
ORGANIZATIONARTICLE XII ACCOUNTING
ORGANIZATIONSection 12.03 Reports
ORGANIZATIONPartner Tax Basis
ORGANIZATION