Foreign Partners. If the Joint Venture withholds any income tax with respect to any foreign Partner pursuant to Sections 1441, 1442, 1445 or 1446 of the Code, the Joint Venture will, at its option, either (x) require the foreign Partner to repay such amount to the Joint Venture within 45 days thereafter; or (y) offset any distributions otherwise payable to the foreign Partner by the amount of such payments.
Foreign Partners. In the event the Partnership is required to withhold taxes with respect to the Net Profits of a Partner who is a foreign person or entity, the General Partners may require an additional Capital Contribution (without adjustment to Exhibit A) of such Partner in the amount of the required withholding amount.
Foreign Partners. 71 Section 14.1 Certification of Non-Foreign Status........................71 Section 14.2 Withholding of Certain Amounts Attributable to Interests of Foreign Partners........................................72 ARTICLE 15 MISCELLANEOUS...................................................72 Section 15.1 Law Governing..............................................72 Section 15.2
Foreign Partners. (a) Notwithstanding anything to the contrary contained herein, the General Partner, on behalf of the Partnership, shall use its best efforts to conduct the affairs of the Partnership in a manner that, under laws, regulations, administrative interpretations and judicial decisions in effect from time to time, does not cause any Limited Partner (or a partner of a Limited Partner) that is not a "United States person" (as that term is defined in Section 7701 of the Code) (such Limited Partner being herein referred to as a "Foreign Partner") to recognize net income effectively connected with the "conduct of a trade or business within the United States" for purposes of Sections 871 and 881 of the Code.
Foreign Partners
