Deemed Capital Contributions. Consistent with the principles of Treasury Regulation Section 1.83-6(d), if any Partner (or its successor) transfers property (including cash) to any employee or other service provider of the Partnership Group and such Partner is not entitled to be reimbursed by (or otherwise elects not to seek reimbursement from) the Partnership for the value of such property, then for tax purposes, (x) such property shall be treated as having been contributed to the Partnership by such Partner and (y) immediately thereafter the Partnership shall be treated as having transferred such property to the employee or other service provider.
Appears in 5 contracts
Samples: Transaction Agreement (Hess Midstream Partners LP), Hess Midstream Partners LP, Hess Midstream Partners LP
Deemed Capital Contributions. Consistent with the principles of Treasury Regulation Section 1.83-6(d), if any Partner (or its successor) transfers property (including cash) to or on behalf of any employee or other service provider of the Partnership Group and such Partner is not entitled to be reimbursed by (or otherwise elects not to seek reimbursement from) the Partnership for the value of such property, then for tax purposes, (x) such property shall be treated as having been contributed to the Partnership by such Partner and (y) immediately thereafter the Partnership shall be treated as having transferred such property to or on behalf of the employee or other service provider.
Appears in 5 contracts
Samples: Agreement (Dominion Energy Midstream Partners, LP), Agreement (Dominion Midstream Partners, LP), Registration Rights Agreement (Dominion Midstream Partners, LP)
Deemed Capital Contributions. Consistent with the principles of Treasury Regulation Section 1.83-6(d), if any Partner (or its successor) transfers property (including cash) to any employee or other service provider of the Partnership Group and such Partner is not entitled to be reimbursed by (or otherwise elects not to seek reimbursement from) the Partnership for the value of such property, then for tax purposes, (x) such property shall be treated as having been contributed to the Partnership by such Partner and (y) immediately thereafter the Partnership shall be treated as having transferred such property to the employee or other service provider.
Appears in 2 contracts
Samples: Agreement, Green Plains Partners LP
Deemed Capital Contributions. Consistent with the principles of Treasury Regulation Section 1.83-6(d), if any Partner (or its successor) transfers property (including cash) to any employee or other service provider of the Partnership Company Group and such Partner is not entitled to be reimbursed by (or otherwise elects not to seek reimbursement from) the Partnership Company for the value of such property, then for tax purposes, (x) such property shall be treated as having been contributed to the Partnership Company by such Partner and (y) immediately thereafter the Partnership Company shall be treated as having transferred such property to the employee or other service provider.
Appears in 2 contracts
Samples: Agreement (Hess Midstream LP), Transaction Agreement (Hess Midstream Partners LP)
Deemed Capital Contributions. Consistent with the principles of Treasury Regulation Section 1.83-6(d), if any Partner (or its successor) transfers property (including cash) to any employee or other service provider of the Partnership Group and such Partner is not entitled to be reimbursed by (or otherwise elects not to seek reimbursement from) the Partnership for the value of such property, then for tax purposes, (xa) such property shall be treated as having been contributed to the Partnership by such Partner and (yb) immediately thereafter the Partnership shall be treated as having transferred such property to the employee or other service provider.
Appears in 1 contract
Samples: Oasis Midstream Partners LP