Class R Unit definition
Examples of Class R Unit in a sentence
Each Unit shall be classified as a Class A or a Class R Unit, but a Unit may only be classified in one of the foregoing classes.
Absent a contrary determination (i) by a court or other final tax authority or (ii) by the General Partner following the date hereof based on a change in law governing the taxation of any interest in the Partnership issued in connection with the performance of services for or for the benefit of the Partnership, (A) the Partnership and each Partner shall treat each Class R Unit as a ‘‘profits interest’’ within the meaning of Rev.
Upon the actual liquidation of the Partnership, the cash payment of the Class R Unit Liquidation Amount shall be treated as (1) a liquidation distribution from the Partnership to the extent of the section 704(b) capital account attributable to the converted Class R Units and (2) a guaranteed payment for U.S. federal income tax purposes for the excess of the Class R Unit Liquidation Amount in cash over the Section 704(b) capital account balance for each Partner holding such converted Class R Unit.