Incorporation of Agreements. The Exchange Agreement and the Tax Receivable Agreement shall each be treated as part of this Agreement as described in Section 761(c) of the Code and Treasury Regulation Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c).
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Samples: Agreement and Plan of Merger (Och-Ziff Capital Management Group LLC), Letter Agreement (Och-Ziff Capital Management Group LLC), Letter Agreement (Och-Ziff Capital Management Group LLC)
Incorporation of Agreements. The Exchange Agreement and the Tax Receivable Agreement shall each be treated as part of this Agreement as described in Section 761(c761 (c) of the Code and Treasury Regulation Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c).
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