Extract to table

IRC § 752(a) — Increase in Partner's Share of Liabilities Section 752(a) provides that any increase in a partner's share of the liabilities of a partnership, or any increase in a partner's individual liabilities by reason of the assumption by the partner of partnership liabilities, "shall be considered as a contribution of money by such partner to the partnership

IRC § 752(b) — Decrease in Partner's Share of Liabilities Section 752(b) provides that any decrease in a partner's share of the liabilities of a partnership, or any decrease in a partner's individual liabilities by reason of the assumption by the partnership of such individual liabilities, "shall be considered as a distribution of money by the partnership to such partner

IRC § 752(c) — Definition of Liability Section 752(c) provides that, for purposes of § 752, a liability to which property is subject shall, to the extent of the fair market value of such property, be treated as a liability of the owner of the property

752-1(f) provides as follows: "If, as the result of a single transaction, a partner incurs both an increase and a decrease in the partner's share of the liabilities of a partnership (or patnerships [sic]), only the net increase or decrease shall be taken into account in applying section 752

The analysis must be conducted at the individual partner level to confirm that no partner is adversely affected

Nordhaven Sovereign Wealth Fund, which holds interests in both Fund IV-A Cayman and Fund V-A Cayman) will have separate liability shares in each vehicle, which must be aggregated for purposes of the pre-reorganization baseline