Classification of Series 4 Units as Equity Clause Samples

Classification of Series 4 Units as Equity. Each of the Managing General Partner, the Partnership, and the holders of the Series 4 Units shall treat the Series 4 Units as equity for all U.S. federal, state, and local income tax purposes, and neither the Managing General Partner, the Partnership, nor any holder of Series 4 Units shall take any position on any U.S. federal, state, or local income or franchise tax return that is inconsistent with such treatment, unless there is a Change in Tax Law that, based on the advice of nationally-recognized counsel experienced as to such matters, requires different reporting and treatment.