Compliance with Treasury Regulations. The foregoing provisions and the other provisions of this Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulation Section 1.704-1(b) (or any corresponding provision of succeeding law) and shall be interpreted and applied in a manner consistent with such Regulation. In the event the General Partner shall determine and the Majority Limited Partners approve that it is prudent to modify the manner in which the Capital Accounts, or any debits or credits thereto, are computed in order to comply with such Regulation, the Partnership may make such modifications. The Partnership also shall make any appropriate modifications in the event unanticipated events might otherwise cause this Agreement not to comply with Treasury Regulation Section 1.704-1(b) (or any corresponding provisions of succeeding law).
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Samples: Partnership Agreement (Penske Automotive Group, Inc.), Limited Partnership Agreement (Penske Automotive Group, Inc.), Limited Partnership Agreement (Penske Automotive Group, Inc.)
Compliance with Treasury Regulations. The foregoing provisions and the other provisions of this Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulation Section 1.704-1(b) (or any corresponding provision of succeeding lawLaw) and shall be interpreted and applied in a manner consistent with such Regulation. In the event the General Partner shall determine and the Majority Limited Partners and the GE Representative Partner approve that it is prudent to modify the manner in which the Capital Accounts, or any debits or credits thereto, are computed in order to comply with such Regulation, the Partnership may make such modifications. The Partnership also shall make any appropriate modifications in the event unanticipated events might otherwise cause this Agreement not to comply with Treasury Regulation Section 1.704-1(b) (or any corresponding provisions of succeeding lawLaw provided that such modification shall not have a material adverse effect on the economic position of any Partner).
Appears in 1 contract
Samples: Agreement of Limited Partnership (Penske Automotive Group, Inc.)
Compliance with Treasury Regulations. The foregoing provisions and the other provisions of this Agreement relating to the maintenance of Capital Accounts capital accounts are intended to comply with Treasury Regulation Section 704(b) of the Code and Treas. Reg. §§1.704-1(bl(b) and 1.704-2 (or any corresponding provision of succeeding law) and shall be interpreted and applied in a manner consistent with such Regulation. In the event the General Partner shall determine and the Majority Limited Partners approve that it is prudent to modify the manner in which the Capital Accounts, or any debits or credits thereto, are computed in order to comply with such Regulation, the Partnership may make such modifications. The Partnership also shall make any appropriate modifications in the event unanticipated events might otherwise cause this Agreement not to comply with Treasury Regulation Section 704(b) of the Code and Treas. Reg. §§1.704-1(bl(b) and 1.704-2 (or any corresponding provisions provision of succeeding law).
Appears in 1 contract
Samples: Limited Partnership Agreement (Graham Packaging Acquisition Corp.)
Compliance with Treasury Regulations. The foregoing provisions and the other provisions of this Agreement relating to the maintenance of Capital Accounts capital accounts are intended to comply with Treasury Regulation Section 704 (b) of the Code and Treas. Reg. §§1.704-1(bl (b) and 1.704-2 (or any corresponding provision of succeeding law) and shall be interpreted and applied in a manner consistent with such Regulation. In the event the General Partner shall determine and the Majority Limited Partners approve that it is prudent to modify the manner in which the Capital Accounts, or any debits or credits thereto, are computed in order to comply with such Regulation, the Partnership may make such modifications. The Partnership also shall make any appropriate modifications in the event unanticipated events might otherwise cause this Agreement not to comply with Treasury Regulation Section 704 (b) of the Code and Treas. Reg. §§1.704-1(bl (b) and 1.704-2 (or any corresponding provisions provision of succeeding law).
Appears in 1 contract
Samples: Agreement of Limited Partnership (Graham Packaging Acquisition Corp.)