Pre-Exchange Transfer definition

Pre-Exchange Transfer means any transfer or distribution in respect of one or more Common Units (i) that occurs prior to an Exchange of such Common Units, and (ii) to which Section 743(b) or 734(b) of the Code applies.

Pre-Exchange Transfer means, with respect to an LLC Unit, any transfer (including upon the death of an LLC Unit Holder) (i) that occurs prior to an Exchange of such LLC Unit or LLC Units and (ii) to which Section 743(b) of the Code applies.

Pre-Exchange Transfer means any transfer (including upon the death of a Member) or distribution in respect of one or more Units (i) that occurs prior to an Exchange of such Units, and (ii) to which Section 743(b) or 734(b) of the Code applies.

Examples of Pre-Exchange Transfer in a sentence

• Notwithstanding any other provision of this Agreement, the amount of any Basis Adjustment or Section 704(c) Allocation Amount resulting from an Exchange of one or more Common Units is to be determined as if any Pre-Exchange Transfer of such Common Units had not occurred.

• Notwithstanding any other provision of this Agreement, the amount of any Basis Adjustment resulting from an Exchange of one or more Common Units is to be determined as if any Pre-Exchange Transfer of such Common Units had not occurred.

• The amount of any Basis Adjustment resulting from an Exchange of one or more LLC Units will be determined without regard to any Pre-Exchange Transfer of the LLC Unit, and as if any such Pre-Exchange Transfer had not occurred.

• Notwithstanding any other provision of this Agreement, the amount of any Basis Adjustment resulting from the CF OMS Sale, an Exchange of one or more Common Units or Earnout Units shall be determined without regard to any Pre-Exchange Transfer of such Common Units and as if any such Pre-Exchange Transfer had not occurred.

• Notwithstanding any other provision of this Agreement, the amount of any Basis Adjustment resulting from an Exchange of one or more Partnership Units shall be determined without regard to any Pre-Exchange Transfer of such Partnership Units, and as if any such Pre-Exchange Transfer had not occurred.

More Definitions of Pre-Exchange Transfer

Pre-Exchange Transfer means any transfer of one or more Partnership Interests (i) that occurs prior to an Exchange of such Partnership Interests, and (ii) to which Section 743(b) applies.

Pre-Exchange Transfer means any transfer of one or more RTEA Units that occurs prior to an Exchange of such RTEA Units.

Pre-Exchange Transfer means any transfer (including upon the death of a Member) of one or more Appleton Class B Exchangeable Units (i) that occurs prior to an Exchange of such Class B Exchangeable Units, and (ii) to which Section 743(b) of the Code applies.

Pre-Exchange Transfer means any transfer (including upon the death of a Limited Partner) of one or more Partnership Units (i) that occurs prior to an Exchange of such Partnership Units, and (ii) to which Section 734(b) or 743(b) of the Code applies.

Pre-Exchange Transfer means any transfer of one or more Company Units (including upon the death of a Member) (i) that occurs after the Business Combination but prior to a Redemption or Direct Exchange or other Exchange of such Units and (ii) to which Section 743(b) of the Code applies (other than such a transfer giving rise to basis adjustments described under Section 1.743-1(h) of the Treasury Regulations).

Pre-Exchange Transfer means any transfer (including upon the death of a Seller) or distribution in respect of one or more Exchangeable Interests (a) that occurs prior to an Exchange of such Exchangeable Interests, and (b) to which Section 743(b) or 734(b) of the Code applies.

Pre-Exchange Transfer means any transfer (including upon the death of a member) of one or more Operating Subsidiaries Group Units (i) that occurs prior to an Exchange of such Operating Subsidiaries Group Units, and (ii) to which Section 743(b) of the Code applies.