Basis Adjustments. The Parties acknowledge and agree to treat (a) to the fullest extent permitted by law each Direct Exchange as giving rise to Basis Adjustments and (b) to the fullest extent permitted by law each Redemption using Class A Common Stock contributed to the Company by the Corporation as a direct purchase of Units by the Corporation from the applicable TRA Holder pursuant to Section 707(a)(2)(B) of the Code as giving rise to Basis Adjustments.
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Samples: Tax Receivable Agreement (Flyexclusive Inc.), Operating Agreement (EG Acquisition Corp.)
Basis Adjustments. The To the fullest extent permitted by law, the Parties acknowledge and agree to treat (ai) to the fullest extent permitted by law each Direct Exchange as giving rise to Basis Adjustments and (bii) to the fullest extent permitted by law each Redemption using cash or Class A Common Stock contributed to the Company LLC by the Corporation as a direct purchase of Common Units by the Corporation from the applicable Exchange TRA Holder pursuant to Section 707(a)(2)(B) of the Code as giving rise to Basis Adjustments.
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Samples: Tax Receivable Agreement (QualTek Services Inc.), Tax Receivable Agreement (Roth CH Acquisition III Co)
Basis Adjustments. The Parties acknowledge and agree to treat (aA) to the fullest extent permitted by law each Direct Exchange as giving rise to Basis Adjustments and (bB) to the fullest extent permitted by law each Redemption using cash or Class A Common Stock contributed to the Company LLC by the Corporation as a direct purchase of Units by the Corporation from the applicable Exchange TRA Holder pursuant to Section 707(a)(2)(B) of the Code as giving rise to Basis Adjustments.
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Basis Adjustments. The Parties acknowledge and agree to treat (aA) to the fullest extent permitted by law each Direct Exchange as giving rise to Basis Adjustments and (bB) to the fullest extent permitted by law each Redemption using Class A Common Stock contributed to the Company LLC by the Corporation as a direct purchase of Units by the Corporation from the applicable TRA Holder pursuant to Section 707(a)(2)(B) of the Code as giving rise to Basis Adjustments.
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