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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
NERS: Each Person who shall sign a Limited Partner Signature Page in the form attached in the Subscription Agreement and who shall be accepted by the General Partner to the Fund as a Limited Partner. DOC ID - 26354060.5 EFTA00803556
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
NERS: Each Person who shall sign a Limited Partner Signature Page in the form attached in the Subscription Agreement and who shall be accepted by the General Partner to the Fund as a Limited Partner. DOC ID - 26354060.5 EFTA00614700
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)
NERS: Each Person who shall sign a Limited Partner Signature Page in the form attached in the Subscription Agreement and who shall be accepted by the General Partner to the Fund as a Limited Partner. DOC ID - 26354060.5 EFTA00614658
Entities connected to both the Partnership Minimum Gain and the General Partner to the Fund
the Initial Closing
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
ORGANIZATION
United States
LOCATIONSection 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