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 agree that it is their intent that to the extent that consideration for the transfer of the Company Interests takes the form of the issuance of Units, the transactions contemplated hereby shall be treated for federal income tax purposes pursuant to Section 721 of the Internal Revenue Code of 1986, as amended (the "Code"), as the contribution of the Company Interests (or portion thereof) by the Contributor to the Acquirer, in exchange for the Units.

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 agree that it is their intent that to the extent that consideration for the transfer of the Company Interests Entity Interest takes the form of the issuance of Units, Units the transactions contemplated hereby shall be treated for federal income tax purposes purposes, pursuant to Section 721 of the Internal Revenue Code of 1986, as amended (the "Code"), as the contribution of the Company Interests (or portion thereof) by the Contributor Contributors to the Acquirer, in exchange for the Units.