Common use of Disclosure of Tax Treatment Clause in Contracts

Disclosure of Tax Treatment. Except as reasonably necessary to comply with applicable securities laws and notwithstanding anything in this Agreement or the other agreements pertaining to the Company to the contrary (collectively, the “Transaction Documents”), such Transaction Documents do not prevent, and have never prevented, any Member (and each employee, representative, or other agent of such Member) from disclosing to any and all Persons, without limitation of any kind, the U.S. federal income tax treatment and tax structure (as those terms are defined in the applicable Treasury Regulations) of the Company and all materials of any kind (including opinions or other tax analyses) that have been or will be provided to such Members relating to such tax treatment and tax structure; provided that a Member must notify the Manager promptly of any request for such information. In interpreting the immediately preceding sentence, it is the intent of the Members that they have been and are expressly authorized to disclose whatever information is necessary and/or required such that the Company will not be a “confidential transaction” within the meaning of either Treasury Regulation §1.6011-4(b)(3) or Treasury Regulation §301.6111-2(c), as such regulations may be amended, modified or clarified. For these purposes, “tax structure” is limited to facts relevant to the U.S. federal income tax treatment of the Company and does not include information relating to the identity of the Members or their Affiliates.

Disclosure of Tax Treatment. Except as reasonably necessary to comply with applicable securities laws and notwithstanding anything in this Agreement or the other agreements pertaining to the Company Partnership to the contrary (collectively, the “Transaction Documents”), such Transaction Documents do not prevent, and have never prevented, any Member Partner (and each employee, representative, or other agent of such MemberPartner) from disclosing to any and all Personspersons, without limitation of any kind, the U.S. federal income tax treatment and tax structure (as those terms are defined in the applicable Treasury Regulations) of the Company Partnership and all materials of any kind (including opinions or other tax analyses) that have been or will be provided to such Members Partners relating to such tax treatment and tax structure; provided that a Member Partner must notify the Manager General Partner promptly of any request for such information. In interpreting the immediately preceding sentence, it is the intent of the Members Partners that they have been and are expressly authorized to disclose whatever information is necessary and/or required such that the Company Partnership will not be a “confidential transaction” within the meaning of either Treasury Regulation §1.6011-4(b)(3) or Treasury Regulation §301.6111-301.6111- 2(c), as such regulations may be amended, modified or clarified. For these purposes, “tax structure” is limited to facts relevant to the U.S. federal income tax treatment of the Company Partnership and does not include information relating to the identity of the Members Partners or their Affiliates.

Disclosure of Tax Treatment. Except as reasonably necessary to comply with applicable securities laws and notwithstanding anything in this Agreement or the other agreements pertaining to the Company Partnership to the contrary (collectively, the “Transaction Documents”), such Transaction Documents do not prevent, and have never prevented, any Member Partner (and each employee, representative, or other agent of such MemberPartner) from disclosing to any and all Personspersons, without limitation of any kind, the U.S. federal income tax treatment and tax structure (as those terms are defined in the applicable Treasury Regulations) of the Company Partnership and all materials of any kind (including opinions or other tax analyses) that have been or will be provided to such Members Partners relating to such tax treatment and tax structure; provided that a Member Partner must notify the Manager General Partner promptly of any request for such information. In interpreting the immediately preceding sentence, it is the intent of the Members Partners that they have been and are expressly authorized to disclose whatever information is necessary and/or required such that the Company Partnership will not be a “confidential transaction” within the meaning of either Treasury Regulation §1.6011-4(b)(3) or Treasury Regulation §301.6111-2(c), as such regulations may be amended, modified or clarified. For these purposes, “tax structure” is limited to facts relevant to the U.S. federal income tax treatment of the Company Partnership and does not include information relating to the identity of the Members Partners or their Affiliates.