Noncompensatory Option definition

Noncompensatory Option has the meaning set forth in Treasury Regulation Section 1.721-2(f).

Noncompensatory Option is defined in Regulations Section 1.721-2(f).

Noncompensatory Option means a “noncompensatory option” within the meaning of Regulations Sections 1.721-2(f) and 1.761-3(b)(2). For purposes of clarification, the Series E Preferred Units, the Series F Preferred Units and the Series G Preferred Units shall be treated as Noncompensatory Options.

Examples of Noncompensatory Option in a sentence

• If, as a result of the exercise of a Noncompensatory Option, including the conversion of Series A Preferred Units into Common Units, the General Partner determines that a Capital Account reallocation pursuant to Regulations Section 1.704-1(b)(2)(iv)(s)(3) is necessary or advisable, the Partnership shall make corrective allocations pursuant to Regulation Section 1.704-1(b)(4)(x).

• In respect of any Noncompensatory Option, the Company shall comply with the rules of Treasury Regulations Sections 1.721-2, 1.761-3, 1.704- 1(b)(2)(iv)(d)(4),1.704-1(b)(2)(iv)(h)(2), 1.704-1(b)(2)(iv)(s), 1.704-1(b)(4)(ix), and 1.704- 1(b)(4)(x), including, without limitation, the rules thereunder requiring (i) allocations of items of income, gain and loss for purposes of maintaining capital accounts, (ii) capital account reallocations, and (iii) corrective allocations.

• If, as a result of an exercise of a Noncompensatory Option to acquire an interest in the Partnership, a Capital Account reallocation is required under Regulations Section 1.704- 1(b)(2)(iv)(s)(3), the Partnership shall make corrective allocations pursuant to Regulations Section 1.704-1(b)(4)(x).

• If, as a result of an exercise of a Noncompensatory Option to acquire an interest in the Company, a Capital Account reallocation is required under Treasury Regulations Section 1.704-1(b)(2)(iv)(s)(3), the Partnership shall make corrective allocations pursuant to Treasury Regulations Section 1.704- 1(b)(4)(x).

More Definitions of Noncompensatory Option

Noncompensatory Option means a “noncompensatory option” within the meaning of Treasury Regulation Sections 1.721-2(f) and 1.761-3(b)(2) issued by the Partnership which, as of the date such option is issued by the Partnership, is not treated as a partnership interest pursuant to Treasury Regulation Section 1.761-3(a).

Noncompensatory Option means a “noncompensatory option” within the meaning of Regulations Sections 1.721-2(f) and 1.761-3(b)(2).

Noncompensatory Option has the meaning set forth in Treasury Regulation Section 1.721-2(f) and includes, for the avoidance of doubt, the Option and all Warrants.

Noncompensatory Option has the meaning set forth in Treasury Regulation Section 1.721-2(f). “Nonrecourse Built-in Gain” means with respect to any Contributed Properties or Adjusted Properties that are subject to a mortgage or pledge securing a Nonrecourse Liability, the amount of any taxable gain that would be allocated to the Partners pursuant to Sections 6.2(b)(i)(A), 6.2(b)(ii)(A) and 6.2(b)(iii) if such properties were disposed of in a taxable transaction in full satisfaction of such liabilities and for no other consideration.

Noncompensatory Option means a “noncompensatory option” within the meaning of Regulations Sections 1.721-2(f) and 1.761-3(b)(2). For purposes of clarification, the conversion feature of the Series A Preferred Units shall be treated as Noncompensatory Options.

Noncompensatory Option has the meaning set forth in Treasury Regulations Section 1.721-2(f). “Nonrecourse Deductions” has the meaning assigned to that term in Treasury Regulations Section 1.704-2(b).

Noncompensatory Option means any of the following if not issued in connection with the performance of services to, or for the benefit of, the Company: