Common use of Section 754 Elections Clause in Contracts

Section 754 Elections. To the extent that the Partnership or any Subsidiary of the Partnership that is treated as a partnership for U.S. federal income tax purposes has not previously made a valid election under Section 754 of the Code (and a corresponding election under state and local law), the Partnership shall make, and shall cause any such Subsidiary of the Partnership to make, such election effective starting with the taxable year that includes the Effective Time, and the General Partner shall not take any action to revoke such elections.