Blackstone Partnership Agreement. This SMD Agreement shall be treated as part of the Blackstone Partnership Agreement for purposes of Section 761(c) of the Internal Revenue Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations. Unless otherwise determined by Blackstone, the amounts payable hereunder shall be paid to you in your capacity as a member or partner of one or more applicable Blackstone Entities and shall be appropriately reflected on your IRS Schedule(s) K-1. The parties do not intend to create an employer-employee relationship hereby and no amounts payable hereunder shall be treated as compensation paid to an employee for tax purposes. You covenant and agree that you will pay all U.S. federal, state, local and foreign taxes on the amounts payable hereunder that are required by law to be paid by you.
Appears in 2 contracts
Samples: Letter Agreement, Letter Agreement (Blackstone Group L.P.)
Blackstone Partnership Agreement. This SMD Agreement shall be treated as part of the Blackstone Partnership Agreement for purposes of Section 761(c) of the Internal Revenue Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations. Unless otherwise determined by Blackstone, the The amounts payable hereunder shall be paid to you in your capacity as a member or partner of one or more the applicable Blackstone Entities Entity and shall be appropriately reflected on your IRS Schedule(s) K-1. The parties do not intend to create an employer-employee relationship hereby and no amounts payable hereunder shall be treated as compensation paid to an employee for tax or other purposes. You covenant and agree that you will pay all U.S. federal, state, local and foreign taxes on the amounts payable hereunder that are required by law to be paid by you.
Appears in 2 contracts
Samples: Blackstone Group L.P., Blackstone Group L.P.
Blackstone Partnership Agreement. This SMD Agreement shall be treated as part of the partnership agreements of Blackstone Partnership Agreement Holdings for purposes of Section 761(c) of the Internal Revenue Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations. Unless otherwise determined by Blackstone, the amounts payable hereunder shall be paid to you in your capacity as a member or partner of one or more applicable Blackstone Entities and shall be appropriately reflected on your IRS Schedule(s) K-1. The parties do not intend to create an employer-employee relationship hereby and no amounts payable hereunder shall be treated as compensation paid to an employee for tax purposes. You covenant and agree that you will pay all U.S. federal, state, local and foreign taxes on the amounts payable hereunder that are required by law to be paid by you.
Appears in 2 contracts
Samples: Letter Agreement, Letter Agreement (Blackstone Group L.P.)