Inconsistent Treatment of Partnership Items Sample Clauses

Inconsistent Treatment of Partnership Items. If any Partner intends to file a notice of inconsistent treatment under section 6222(b) of the Code, then such Partner shall give reasonable notice under the circumstances to the other Partners of such intent and the manner in which the Partner's intended treatment of an item is (or may be) inconsistent with the treatment of that item by the other Partners.
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Inconsistent Treatment of Partnership Items. If any Party intends to file a notice of inconsistent treatment under Code §6222(b), such Party shall, prior to the filing of such notice, notify the TMP of the (actual or potential) inconsistency of the Party’s intended treatment of a partnership item with the treatment of that item by the Partnership. Within one week of receipt the TMP shall remit copies of such notification to the other Parties. If an inconsistency notice is filed solely because a Party has not received a Schedule K-1 in time for filing of its income tax return, the TMP need not be notified.
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Inconsistent Treatment of Partnership Items. No Limited Partner shall file a notice of inconsistent treatment under section 6222(b) of the Code with respect to the treatment of Partnership items.
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Inconsistent Treatment of Partnership Items. No Limited Partner shall file a notice of inconsistent treatment under section 6222(b) of the Code with respect to the treatment of Partnership items. EXHIBIT 6.2(a) BOARD OF MANAGERS EnCap Designees Xxxx X. Xxxxxxxxx, Xx. Xxxxxxx X. Xxxxxxx, Xx. Xxxxxx X. Xxxxxx D. Xxxxxx Xxxxxxxx Management Entities’ Designees Xxxxxxxx X. Xxxxxxx Xxxxxxxxxxx X. Xxxxxxx Xxxxxx X. Xxxxxxxxxx Exhibit 6.2(a) EXHIBIT 6.9 OFFICERS Name Office Xxxxxxxx X. Xxxxxxx President and Chief Executive Officer Xxxxxx X. Xxxxxxxxxx Executive Vice President and Chief Operating Officer Xxxxxxx XxXxxxx Executive Vice President and Chief Financial Officer Xxxxxxxxxxx X. Xxxxxxx Executive Vice President, Secretary, and General Counsel Xxx Xxxxxxx Vice President and Chief Accounting Officer Xxxx Xxxx Vice President and Controller Xxxxx Xxxxxx Vice President, Administration Xxxxxx X. Xxxxxxx Assistant Secretary
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Inconsistent Treatment of Partnership Items. If either Party intends to file a notice of inconsistent treatment under Section 6222(b) of the Code, such Party shall, at least thirty (30) days prior to the filing of such notice, notify the other Party of such intent and the manner in which the Party’s intended treatment of a Tax Partnership item is (or may be) inconsistent with the treatment of that item by the Tax Partnership, and advise the other Party of the reasons therefor.
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Inconsistent Treatment of Partnership Items. If any Member intends to file a notice of inconsistent treatment under ss.6222(b) of the Code, the Member shall, at least thirty (30) days prior to the filing of the notice, provide a Notification to the Tax Matters Member and the other Members of its intent and the manner in which the Member's intended treatment of a Company item is (or may be) inconsistent with the treatment of that item by the Company, and advise the Tax Matters Member and the other Members of the reasons therefor. Notwithstanding the preceding, the Members are not required to provide notice where estimated rather than actual partnership amounts are incorporated in partner tax filings.
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Inconsistent Treatment of Partnership Items. If any Partner intends to file a notice of inconsistent treatment under section 6222(b) of the Code, then such Partner shall give reasonable notice under the circumstances to the other Partners of such intent and the manner in which the Partner's intended treatment of an item is (or may be) inconsistent with the treatment of that item by the other Partners. XXXXXXX X XXXXXXXXXXX XX XXXX XXX XXXXXXX EXHIBIT E AGREED VALUE OF EACH PROPERTY EXHIBIT F REPRESENTATIONS AND WARRANTIES OF TSL REGARDING PARTNERSHIP AND RELATED MATTERS
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Related to Inconsistent Treatment of Partnership Items

  • Consistent Treatment Unless and until there has been a Final Determination to the contrary, each Party agrees not to take any position on any Tax Return, in connection with any Tax Contest or otherwise that is inconsistent with (i) the treatment of payments between the Parent Group and the SpinCo Group as set forth in Section 5.4, (ii) the Tax Materials or (iii) the Intended Tax Treatment.

  • Revisions to Allocations to Reflect Issuance of Partnership Interests If the Partnership issues Partnership Interests to the General Partner or any additional Limited Partner pursuant to Article IV, the General Partner shall make such revisions to this Article 6 and Exhibit B as it deems necessary to reflect the terms of the issuance of such Partnership Interests, including making preferential allocations to classes of Partnership Interests that are entitled thereto. Such revisions shall not require the consent or approval of any other Partner.

  • Allocation of Registration Opportunities In any circumstance in which all of the Registrable Securities and other shares of the Company with registration rights (the “Other Shares”) requested to be included in a registration contemplated by Section 2(a) cannot be so included as a result of limitations of the aggregate number of shares of Registrable Securities and Other Shares that may be so included, the number of shares of Registrable Securities and Other Shares that may be so included shall be allocated among the Holders and Other Shareholders requesting inclusion of shares pro rata on the basis of the number of shares of Registrable Securities and Other Shares held by such Holders and Other Shareholders; provided, however, that such allocation shall not operate to reduce the aggregate number of Registrable Securities and Other Shares to be included in such registration, if any Holder or Other Shareholder does not request inclusion of the maximum number of shares of Registrable Securities and Other Shares allocated to such Holder or Other Shareholder pursuant to the above-described procedure, then the remaining portion of such allocation shall be reallocated among those requesting Holders and Other Shareholders whose allocations did not satisfy their requests pro rata on the basis of the number of shares of Registrable Securities and Other Shares which would be held by such Holders and Other Shareholders, assuming conversion, and this procedure shall be repeated until all of the shares of Registrable Securities and Other Shares which may be included in the registration on behalf of the Holders and Other Shareholders have been so allocated.

  • REIT Treatment The Company will use its best efforts to meet the requirements to qualify as a “real estate investment trust” under the Code for any taxable years that include any portion of the term of this Agreement.

  • Formation of Partnership The Partnership was formed on August 3, 2018 pursuant to the provisions of the Delaware Act.

  • Management of Partnership Section 2.01

  • Accounting Treatment For accounting purposes, the Merger is intended to be treated as a "purchase."

  • Tax and Accounting Treatment Each party to this Agreement acknowledges that it is its intent for purposes of U.S. federal, state and local income and franchise taxes, and for accounting purposes, to treat each Transaction as indebtedness of Seller that is secured by the Purchased Mortgage Loans and that the Purchased Mortgage Loans are owned by Seller in the absence of a Default by Seller. All parties to this Agreement agree to such treatment and agree to take no action inconsistent with this treatment, unless required by applicable Requirements of Law or GAAP.

  • Certification of Limited Liability Company and Limited Partnership Interests Each interest in any limited liability company or limited partnership controlled by any Grantor and pledged hereunder shall be represented by a certificate, shall be a “security” within the meaning of Article 8 of the New York UCC and shall be governed by Article 8 of the New York UCC.

  • Termination of Partnership and Cancellation of Certificate of Limited Partnership Upon the completion of the liquidation of the Partnership’s assets, as provided in Section 13.2 hereof, the Partnership shall be terminated, a certificate of cancellation shall be filed, and all qualifications of the Partnership as a foreign limited partnership in jurisdictions other than the state of Delaware shall be canceled and such other actions as may be necessary to terminate the Partnership shall be taken.

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