Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 19 contracts
Samples: Limited Partnership Agreement (Blackstone Group Inc), Limited Partnership Agreement (Blackstone Group Inc), Limited Partnership Agreement (Blackstone Group Inc)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.5(g) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1T(b)(4)(xi1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 11 contracts
Samples: Limited Partnership Agreement (Ares Management Corp), Limited Partnership Agreement (Ares Management Corp), Limited Partnership Agreement (Ares Management Lp)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.5(f) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1T(b)(4)(xi1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 8 contracts
Samples: Limited Partnership Agreement (Ares Management Lp), Limited Partnership Agreement (Ares Management Lp), Limited Partnership Agreement (Ares Management Lp)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 5 contracts
Samples: Limited Partnership Agreement (GWG Holdings, Inc.), Limited Partnership Agreement (GWG Holdings, Inc.), Limited Partnership Agreement (Carlyle Group L.P.)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi1 (b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 5 contracts
Samples: Limited Partnership Agreement (KKR & Co. L.P.), Limited Partnership Agreement (KKR & Co. L.P.), Limited Partnership Agreement (KKR & Co. L.P.)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.07(f) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Apollo Global Management LLC), Limited Partnership Agreement (Apollo Global Management LLC), Limited Partnership Agreement (Apollo Global Management LLC)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.05(g) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1T(b)(4)(xi1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 3 contracts
Samples: Limited Partnership Agreement (Carlyle Group L.P.), Limited Partnership Agreement (Carlyle Group L.P.), Limited Partnership Agreement (Carlyle Group L.P.)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi1T(b) (4)(xi), and shall be interpreted consistently therewith.
Appears in 3 contracts
Samples: Limited Partnership Agreement (Blackstone Group Inc), Limited Partnership Agreement (Blackstone Group Inc), Limited Partnership Agreement (Blackstone Group Inc)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Apollo Global Management LLC), Limited Partnership Agreement (Apollo Global Management LLC)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Beneficient), Limited Partnership Agreement (Beneficient)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi1(b)(4) (viii), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Fifth Street Asset Management Inc.), Limited Partnership Agreement (Fifth Street Asset Management Inc.)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi1(b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Medley Management Inc.), Limited Liability Company Agreement (Medley Management Inc.)
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. Tax relates (under principles of Treasury Regulations Section 1.904-6). The provisions of this Section 5.05(f5.05(j) are intended to comply with the provisions of Temporary Treasury Regulations Section 1.704-1T(b)(4)(xi1 (b)(4)(viii), and shall be interpreted consistently therewith.
Appears in 1 contract
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-Non- U.S. 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 1.704-1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Apollo Global Management LLC
Creditable Non-U.S. Taxes. Creditable Non-U.S. 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 Non-U.S. 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 1.704-1T(b)(4)(xi), and shall be interpreted consistently therewith.
Appears in 1 contract
Samples: Limited Partnership Agreement (Blackstone Group L.P.)