Common use of Compliance with Timing Requirements of Treasury Regulations Clause in Contracts

Compliance with Timing Requirements of Treasury Regulations. Notwithstanding anything in this Article 8 to the contrary, in the event the Partnership is "liquidated" within the meaning of Regulations Section 1.704-1(b)(2)(ii)(g), distributions shall be made to the Partners who have positive Capital Account balances pursuant to Section 4.2 in a manner that complies with Regulations Section 1.704-1(b)(2)(ii)(b)(2). However, a liquidation occurring as a result of a Tax Termination shall not require an actual distribution of Partnership assets, but shall instead be treated as a constructive liquidation and reformation in the manner in Regulations Section 1.708-1(b)(1)(iv), or otherwise as required by successor Regulations, if any.

Compliance with Timing Requirements of Treasury Regulations. Notwithstanding anything in this Article 8 to the contrary, in the event the Partnership Company is "liquidated" within the meaning of Regulations Section 1.704-1(b)(2)(ii)(g), distributions shall be made to the Partners Members who have positive Capital Account balances pursuant to Section 4.2 in a manner that complies with Regulations Section 1.704-1(b)(2)(ii)(b)(2). However, a liquidation occurring as a result of a Tax Termination shall not require an actual distribution of Partnership Company assets, but shall instead be treated as a constructive liquidation and reformation in the manner in Regulations Section 1.708-1(b)(1)(iv), or otherwise as required by successor Regulations, if any.