The passive equity investors, as limited partners, are junior to the lenders; they receive cash distributions out of what is left over after Cogeneration Company pays debt service for the year. The size of the cash distributions is not specified contractually; it depends on the profitability of the Cogeneration Project. The passive equity investors also receive their share of the tax benefits associated with project ownership plus a share of the Cogeneration Project's residual value. To realize these benefits, the passive equity investors had to commit to the construction lenders to invest a stated percentage of the project's equity capital (55.56 percent of limited partnership capital and 50 percent of total equity capital), once the Cogeneration Project passes its completion tests.