Adverse Tax Consequences. No Transfer by a Limited Partner of its Partnership Interests (including any Redemption, any other acquisition of Partnership Units by the Managing General Partner or any acquisition of Partnership Units by the Partnership) may be made to or by any Person if (i) in the opinion of legal counsel for the Partnership, it would (A) 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 (B) adversely affect the ability of the Special Limited Partner to continue to qualify as a REIT or would subject the Special Limited Partner to any additional taxes under Sections 857 or 4987 of the Code 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.
Appears in 6 contracts
Samples: Contribution Agreement (Welsh Property Trust, Inc.), Contribution Agreement (Welsh Property Trust, Inc.), Contribution Agreement (Welsh Property Trust, Inc.)
