Common use of Tax Consequences to Contributor Clause in Contracts

Tax Consequences to Contributor. Notwithstanding anything to the contrary contained in this Agreement, including without limitation the use of words and phrases such as “sell,” “sale,” purchase,” and “pay,” the parties hereto acknowledge and agree that, if and to the extent Contributor elects to take its Consideration in the form of Units, it is their intent that the transaction contemplated hereby be treated for federal income tax purposes as the contribution of the Interests by Contributor to Acquirer in exchange for Units pursuant to Section 721 of the Internal Revenue Code of 1986, as amended (the “Code”), and not as a transaction in which Contributor is acting other than in its capacity as a prospective partner of Acquirer.

Tax Consequences to Contributor. Notwithstanding anything to the contrary contained in this Agreement, including without limitation the use of words and phrases such as “"sell,” “" "sale,” " purchase,” " and “"pay,” " the parties hereto acknowledge and agree that, if and to the extent Contributor elects to take its Consideration in the form of Units, it is their intent that the transaction contemplated hereby be treated for federal income tax purposes as the contribution of the Interests Management Agreements by Contributor to Acquirer in exchange for Units pursuant to Section 721 of the Internal Revenue Code of 1986, as amended (the “"Code”"), and not as a transaction in which Contributor is acting other than in its capacity as a prospective partner of Acquirer.

Tax Consequences to Contributor. Notwithstanding anything to the contrary contained in this Agreement, including without limitation the use of words and phrases such as “sell,” “sale,” purchase,” and “pay,” the parties hereto acknowledge and agree that, if and to the extent Contributor elects to take its Consideration in the form of Units, it is their intent that the transaction contemplated hereby be treated for federal income tax purposes as the contribution of the Interests Management Agreements by Contributor to Acquirer in exchange for Units pursuant to Section 721 of the Internal Revenue Code of 1986, as amended (the “Code”), and not as a transaction in which Contributor is acting other than in its capacity as a prospective partner of Acquirer.