Examples of Development Partnership in a sentence
A third partnership, The Woodlands Operating Company (the "Management Company"), (a) employs the employees previously employed by TWC and will furnish advisory and other services to the Commercial Partnership and the Development Partnership and (b) through a general partnership between itself and a wholly owned corporation, WECCR General Partnership (the "Tenant Partnership"), has leased the hotel and golf courses from the Commercial Partnership.
Whether the Commercial Partnership and the Development Partnership will be considered for federal income tax purposes as separate entities and not as partners of or with each other; 17.
The Cross Reimbursement and Indemnity Agreement provides that the Commercial Partnership and the Development Partnership must indemnify the other against loss occasioned by a failure of the partnership to perform under its loan agreement.
The income of the Commercial Partnership will in general consist of items which meet the requirements of the Gross Income Tests, and the income of the Development Partnership will consist generally of items which either do not meet such requirements or are subject to the tax imposed by section 857 on prohibited transactions.
Furthermore, because of the relatively low level of leverage being employed (approximately 60 percent for the Commercial Partnership and approximately 72 percent for the Development Partnership), no such failure is anticipated.
Whether, assuming that the Commercial Partnership and the Development Partnership are considered to constitute one partnership for federal income tax purposes, the allocation to Crescent Equities under Treas.
Based upon the foregoing, it is our opinion that if, contrary to our opinion, the Commercial Partnership and the Development Partnership are considered to constitute one partnership for federal income tax purposes, the allocations of profit and loss from the leased Properties to the partners of the Commercial Partnership and the allocations of profit and loss from the Development Properties to the partners of the Development Partnership will be respected under section 704.
Accordingly, in our opinion the Commercial Partnership and the Development Partnership will be considered for federal income tax purposes as separate entities and not as partners of or with each other.
In the present case, all the formal expressions of intent indicate that the Commercial Partnership and the Development Partnership are separate.
For purposes of the following discussion it is assumed that, contrary to our opinion, the Commercial Partnership and the Development Partnership are aggregated and considered to constitute a single partnership.