Special Partnership Units. The Advisor has made capital contributions to the Partnership in exchange for certain partnership units as described as follows: $2,000 in exchange for 200 common units and $1,000 in exchange for 100 Special Units. Upon the earliest to occur of the termination of this Agreement for Cause, a Termination Event, or a Listing, all of the Special Units shall be redeemed by the Partnership in accordance with the terms of the Partnership Agreement.
Special Partnership Units. Units of limited partnership interest in the Operating Partnership designated as Special Partnership Units in the in the Operating Partnership Agreement.
Special Partnership Units. Under the Prior Agreement, the Partnership had issued Special Partnership Units (as defined in the Prior Agreement). Prior to the effective date of this Agreement, the Partnership redeemed all of the Special Partnership Units. As of the date of this Agreement, no Special Partnership Units are outstanding and except as provided in Section 4.3, the Partnership is not authorized to issue any Special Partnership Units.
Special Partnership Units. (a) The Partnership and the Partners acknowledge and agree that the Special Partnership Units, and the rights and privileges associated with such Partnership Interest, collectively are intended to constitute a “profits interest” in the Partnership within the meaning of Revenue Procedure 93-27, 1993-2 C.B. 343, or any successor Internal Revenue Service or Regulation or other pronouncement applicable at the date of issuance of such Partnership Interest. For so long as Revenue Procedure 2001-43, 2001-2 C.B. 343, is effective, the Partnership and the Partners hereby agree to comply with the provisions of Revenue Procedure 2001-43, and neither the Partnership nor any Partner shall perform any act or take any position inconsistent with the application of Revenue Procedure 2001-43.
