Common use of Adverse Tax Consequences Clause in Contracts

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, any Redemption, or any other acquisition of Partnership Units by the Partnership or the General Partner) may be made to or by any person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “established securities market” or a “secondary market (or the substantial equivalent thereof)” within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, Interests (including any Redemption, or any other acquisition of Partnership Units by the Partnership or the General Partner) may be made to or by any person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “"established securities market” " or a “"secondary market (or the substantial equivalent thereof)” " within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner Holder of its Partnership InterestsUnits (including any Exchange, any Redemption, or any other acquisition of Partnership Units by the General Partner or any acquisition of Partnership or Units by the General PartnerPartnership and including any Permitted Transfer) may be made to or by any person Person if the Partnership determines, (i) in the opinion such Transfer would create a material risk of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) there would be a material risk that such Transfer would be treated as effectuated through an “established securities market” or a “secondary market (or the substantial equivalent thereof)” within the meaning of Code Section section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, Interests (including any Redemption, or any other acquisition of Partnership Units by the Partnership or the General Partnera REIT Party) may be made to or by any person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “"established securities market” " or a “"secondary market (or the substantial equivalent thereof)” " within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, Interests (including any Redemption, or any other acquisition of Partnership Units by the Managing General Partner or any acquisition of Partnership or Units by the General PartnerPartnership) may be made to or by any person Person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, 708 or (ii) such Transfer would be effectuated through an “"established securities market” " or a “"secondary market (or the substantial equivalent thereof)” " within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, Interests (including any Redemption, or any other acquisition of Partnership Units by the Partnership or the General Partnera REIT Party) may be made to or by any person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “established securities market” or a “secondary market (or the substantial equivalent thereof)” within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, Interests (including any Redemption, or any other acquisition of Partnership Units by the Partnership or the General Partner) may be made to or by any person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “established securities market” or a “secondary market (or the substantial equivalent thereof)” within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, any Redemption, or any other acquisition of Partnership Units by the Partnership or the General Partner) Interests may be made to or by any person Person, other than a Transfer to iStar or its assignees, transferees or designees in connection with a Lender Transfer, if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “"established securities market” " or a “"secondary market (or the substantial equivalent thereof)” " within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, any Redemption, or any other acquisition of Partnership Units by the Partnership or the General Partner) may be made to or by any person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “"established securities market” " or a “"secondary market (or the substantial equivalent thereof)” " within the meaning of Code Section 7704.

Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests, Interests (including any Redemption, or any other acquisition of Partnership Units by the Managing General Partner or any acquisition of Partnership or Units by the General PartnerPartnership) may be made to or by any person Person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation or would result in a termination of the Partnership under Code Section 708, or (ii) such Transfer would be effectuated through an “"established securities market” " or a “"secondary market (or the substantial equivalent thereof)” " within the meaning of Code Section 7704.