Basis Adjustments. The Parties acknowledge and agree that (i) each Redemption and the IPO Unit Redemption shall be treated as a direct purchase of Units by the Corporation from the applicable Member pursuant to Section 707(a)(2)(B) of the Code (or any similar provisions of applicable state, local or foreign tax Law) (i.e., equivalent to a Direct Exchange) and (ii) each Exchange will give rise to Basis Adjustments.
Appears in 5 contracts
Samples: Tax Receivable Agreement (Bridge Investment Group Holdings Inc.), Tax Receivable Agreement (Bridge Investment Group Holdings Inc.), Tax Receivable Agreement (GoHealth, Inc.)
Basis Adjustments. The Parties acknowledge and agree that (i) each Redemption and the IPO Unit Redemption shall be treated as a direct purchase of Units by the Corporation from the applicable Member pursuant to Section 707(a)(2)(B) of the Code (or any similar provisions of applicable state, U.S. state or local or foreign tax Law) (i.e., equivalent to a Direct Exchange) and (ii) each Exchange will give rise to Basis Adjustments.
Appears in 4 contracts
Samples: Tax Receivable Agreement (Marketwise, Inc.), Joinder Agreement (Ascendant Digital Acquisition Corp.), Joinder Agreement (Foresight Acquisition Corp.)
Basis Adjustments. The Parties acknowledge and agree that (i) each Redemption and the IPO Unit Redemption shall be treated as a direct purchase of Units by the Corporation from the applicable Member pursuant to Section 707(a)(2)(B) of the Code (or any similar provisions of applicable state, local or foreign tax Law) (i.e., equivalent to a Direct Exchange) and (ii) each Exchange will give rise to Basis Adjustments.
Appears in 3 contracts
Samples: Tax Receivable Agreement (SciPlay Corp), Tax Receivable Agreement (Scientific Games Corp), Tax Receivable Agreement (SciPlay Corp)
Basis Adjustments. The Parties acknowledge and agree that (i) each Redemption and the IPO Unit Redemption shall be treated as a direct purchase of Class A Units by the Corporation from the applicable Member pursuant to Section 707(a)(2)(B) of the Code (or any similar provisions of applicable state, local or foreign tax Law) (i.e., equivalent to a Direct Exchange) and (ii) each Exchange will give rise to Basis Adjustments.
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