Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f) are intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 16 contracts
Samples: Partnership Agreement (Apollo Global Management LLC), Exempted Limited Partnership Agreement (Apollo Global Management LLC), Partnership Agreement (Apollo Global Management LLC)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partnerspartners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1(b)(4)(viii1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 13 contracts
Samples: Limited Partnership Agreement (Brookfield Oaktree Holdings, LLC), Limited Partnership Agreement (Oaktree Capital Group, LLC), Limited Partnership Agreement (Oaktree Capital Group, LLC)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partnerspartners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f) are intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 5 contracts
Samples: Limited Partnership Agreement (Evercore Inc.), Limited Partnership Agreement (Evercore Partners Inc.), Limited Partnership Agreement (Evercore Partners Inc.)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partnerspartners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f8.2(f) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1(b)(4)(viii1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 5 contracts
Samples: Addendum Agreement (Freescale Semiconductor Inc), Addendum Agreement (Freescale Semiconductor Holdings I, Ltd.), Addendum Agreement (Travelport LTD)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the PartnershipCompany, or an entity owned directly or indirectly by the PartnershipCompany, shall be allocated to the Partners Members in proportion to the PartnersMembers’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f) are intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Apollo Global Management LLC), Limited Liability Company Operating Agreement (Edgen Group Inc.), Limited Liability Company Operating Agreement (Edgen Group Inc.)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the PartnershipCompany, or an entity owned directly or indirectly by the PartnershipCompany, shall be allocated to the Partners Members in proportion to the PartnersMembers’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f(f) are intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Apollo Global Management LLC), Limited Liability Company Agreement (Apollo Global Management LLC)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the PartnershipCompany, or an entity owned directly or indirectly by the PartnershipCompany, shall be allocated to the Partners Members in proportion to the PartnersMembers’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f) IV.E.6. are intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(4)(viiil(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Operating Agreement (Convergence, LLC), Operating Agreement (Convergence, LLC)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.4(h) are intended to comply with the provisions of temporary Treasury Regulations Section 1.704-1(b)(4)(viii1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Evercore Partners Inc.), Limited Partnership Agreement (Evercore Partners Inc.)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.4(h) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1(b)(4)(viii1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (Evercore Partners Inc.)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partnerspartners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1(b)(4)(viii1T(b)(4)(xi), and shall be interpreted consistently therewith.. (g)
Appears in 2 contracts
Samples: Partnership Agreement (Oaktree Capital Group, LLC), Partnership Agreement (Oaktree Capital Group, LLC)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the PartnershipCompany, or an entity owned directly or indirectly by the PartnershipCompany, shall be allocated to the Partners Members in proportion to the PartnersMembers’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.4(h) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1(b)(4)(viii1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Evercore Partners Inc.)
Creditable Foreign Taxes. Creditable Foreign Taxes for any taxable period attributable to the Partnership, or an entity owned directly or indirectly by the Partnership, shall be allocated to the Partners in proportion to the Partners’ distributive shares of income (including income allocated pursuant to Section 704(c) of the Code) to which the Creditable Foreign Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f) are intended to comply with the provisions of Treasury Regulations Section 1.704-1.704- 1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Apollo Global Management LLC
