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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
er will distribute (x) Net Cash Flow from interest, dividends and income from Temporary Investments at least semi-annually (other than amounts that the General Partner deems de minims in its good faith discretion) and (y) Net Cash Flow from dispositions of, and income from, any Investment as soon as reasonably practicable upon th
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
er will distribute (x) Net Cash Flow from interest, dividends and income from Temporary Investments at least semi-annually (other than amounts that the General Partner deems de minims in its good faith discretion) and (y) Net Cash Flow from dispositions of, and income from, any Investment as soon as reasonably practicable upon th
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)
er will distribute (x) Net Cash Flow from interest, dividends and income from Temporary Investments at least semi-annually (other than amounts that the General Partner deems de minims in its good faith discretion) and (y) Net Cash Flow from dispositions of, and income from, any Investment as soon as reasonably practicable upon th
Entities connected to both the Partnership Minimum Gain and the General Partner deems de minims
Alternative Investment Vehicles or
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