Tax Partnerships. Except as set forth on Schedule 5.25, the Assets are not subject to any tax partnership agreements requiring a partnership income tax return to be filed under Subchapter K of Chapter 1 of Subtitle A of the United States Internal Revenue Code.
Tax Partnerships. Except as disclosed in Schedule 4.1(s), no Property is subject to, or considered to be held by, any partnership for federal income tax purposes, other than tax partnerships under joint operating agreements.
Tax Partnerships. None of the Properties are subject to, or considered to be held by, any tax partnership.
Tax Partnerships. None of the Properties is subject to a tax partnership, including, without limitation, none of such Properties are subject to any operating agreement or other arrangement under which the parties thereto have not made an effective election pursuant to Section 761 of the Internal Revenue Code of 1986 (herein called the “Internal Revenue Code”), and the Treasury Regulations promulgated thereunder, to be excluded from the application of Subchapter K, Chapter 1, Subtitle A, of the Internal Revenue Code.
Tax Partnerships. None of the Purchased Assets are subject to any Tax partnership agreement requiring a partnership income Tax return to be filed under Subchapter K of Chapter 1 of Subtitle A of the Code.
Tax Partnerships. Except as set forth on Schedule 4.18, no Property is subject to any tax partnership agreement or provisions requiring a partnership income tax return to be filed under Subchapter K of Chapter 1 of Subtitle A of the Code or any similar state statute, and in the case of any Property subject to a tax partnership agreement, the tax partnership has an election in effect under Section 754 of the Code.
Tax Partnerships. Except as set forth in Schedule 4.16, none of the Assets is held by or is subject to any contractual arrangement between RTP or EAOC, on the one hand, and any other Person, on the other hand, whether owning undivided interests therein or otherwise, that is classified as a partnership for United States federal Tax purposes (a “Tax Partnership”) and no transfer of any part of the Assets pursuant to this Agreement will be treated as a transfer of an interest or interests in any such partnership, and, to the extent that any of the Assets are deemed by agreement or applicable Law to be held by a partnership for federal Tax purposes, except as set forth in Schedule 4.16, each such partnership has or shall have in effect an election under Section 754 of the Code that will apply with respect to the acquisition by Buyer of the Assets.
Tax Partnerships. The Assets are not subject to any tax partnership agreement requiring a partnership income tax return to be filed under Subchapter K of Chapter 1 of Subtitle A of the United States Internal Revenue Code.
Tax Partnerships. Except as set forth on Schedule 5.20, none of the Assets are subject to or owned by any tax partnership (other than any Seller that is a partnership for U.S. federal income tax purposes) requiring a partnership income Tax Return to be filed under Subchapter K of Chapter 1 of Subtitle A of the Code. Each tax partnership identified in Schedule 5.20 has or shall have in effect an election under Section 754 of the Code that will apply with respect to the acquisition by Buyer of the Assets.
Tax Partnerships. The Properties are not subject to any partnerships that shall not be liquidated prior to Closing.
