Creditable Foreign Taxes. Creditable foreign taxes shall be allocated to the Partnership Unit Holders in accordance with the Partnership Unit Holders’ distributive shares of income (including income allocated pursuant to Code Section 704(c) to which the creditable foreign tax relates. The provisions of this Section 3 are intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(4)(viii).
Appears in 5 contracts
Samples: Limited Partnership Agreement (Artisan Partners Asset Management Inc.), Limited Partnership Agreement (Artisan Partners Asset Management Inc.), Limited Partnership Agreement (Artisan Partners Asset Management Inc.)