Payee Allocation. If any payment to any person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 79 contracts
Sources: Limited Partnership Agreement (Brookfield Real Estate Income Trust Inc.), Limited Partnership Agreement (Blackstone Real Estate Income Trust, Inc.), Limited Partnership Agreement (Blue Owl Digital Infrastructure Trust)
Payee Allocation. If In the event any payment to any person Person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 20 contracts
Sources: Limited Partnership Agreement (Blackstone Multi-Strategy Hedge Fund L.P.), Limited Partnership Agreement (Ares Sports, Media & Entertainment Opportunities LP), Limited Partnership Agreement (Brookfield Private Equity Fund LP)
Payee Allocation. If In the event any payment to any person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partnerPartner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 4 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement (Evercore Partners Inc.), Limited Partnership Agreement (Evercore Partners Inc.)
Payee Allocation. If any payment to any person Person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partnerPartner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 2 contracts
Sources: Limited Partnership Agreement, Limited Partnership Agreement
Payee Allocation. If In the event any payment to any person Person that is treated by the Partnership Fund as the payment of an expense is recharacterized by a taxing authority as a Partnership partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership Fund gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 1 contract
Sources: Limited Partnership Agreement (Macquarie Infrastructure Fund, L.P.)
Payee Allocation. If any payment to any person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 1 contract
Sources: Limited Partnership Agreement (JER Investors Trust Inc)
Payee Allocation. If In the event that any payment to any person Person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 1 contract
Sources: Limited Partnership Agreement (CDL Tender Fund 2022-1, L.P.)