Common use of Beneficial Assets and Subsidiary Beneficial Assets Clause in Contracts

Beneficial Assets and Subsidiary Beneficial Assets. The Partnership shall (and the Partners shall not, except as Partners of the Partnership) report, for Federal income tax purposes, the income, gain, deduction and loss with respect to the Beneficial Assets that are not Subsidiary Beneficial Assets, and the Partners shall (and the Partnership shall not) report, for Federal income tax purposes, the income, gain, deduction and loss with respect to the Subsidiary Beneficial Assets. In the event that, pursuant to any Final Determination (as defined below), the Partnership either (x) is treated as the beneficial owner of any of the Subsidiary Beneficial Assets prior to the actual contribution of such Subsidiary Beneficial Assets to the Partnership or (y) is treated as not the beneficial owner of any of the Beneficial Assets that are not Subsidiary Beneficial Assets prior to the actual contribution of such Beneficial Assets to the Partnership, to the extent necessary, appropriate adjustments shall be made to the distributions provided for in Section 5.1 so as to place the Partners and the Partnership in the same positions they would have been in had the Partnership's beneficial ownership of the Subsidiary Beneficial Assets or lack of beneficial ownership of such other Beneficial Assets been taken into account originally.

Beneficial Assets and Subsidiary Beneficial Assets. The Partnership shall (and the Partners shall not, except as Partners of the Partnership) report, for Federal income tax purposes, the income, gain, deduction and loss with respect to the Beneficial Assets that are not Subsidiary Beneficial Assets, and the Partners shall (and the Partnership shall not) report, for Federal income tax purposes, the income, gain, deduction and loss with respect to the Subsidiary Beneficial Assets. In the event that, pursuant to any Final Determination (as defined below), the Partnership either (x) is treated as the beneficial owner of any of the Subsidiary Beneficial Assets prior to the actual contribution of such Subsidiary Beneficial Assets to the Partnership or (y) is treated as not the beneficial owner of any of the Beneficial Assets that are not Subsidiary Beneficial Assets prior to the actual contribution of such Beneficial Assets to the Partnership, to the extent necessary, appropriate adjustments shall be made to the distributions provided for in Section 5.1 so as to place the Partners and the Partnership in the same positions they would have been in had the Partnership's beneficial ownership of the Subsidiary Beneficial Assets or lack of beneficial ownership of such other Beneficial Assets been taken into account originally.of