Election to be Treated as a Corporation. Notwithstanding anything to the contrary contained herein, if the General Partner determines in its sole discretion that it is no longer in the best interests of the Partnership to continue as a partnership for U.S. federal income tax purposes, the General Partner may elect to treat the Partnership as an association or as a publicly traded partnership taxable as a corporation for U.S. federal (and applicable state) income tax purposes.
Appears in 33 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (BPY Bermuda Holdings IV LTD), Limited Partnership Agreement (Brookfield Renewable Partners L.P.)
Election to be Treated as a Corporation. Notwithstanding anything to the contrary contained herein, if the Managing General Partner determines in its sole discretion that it is no longer in the best interests of the Partnership to continue as a partnership for U.S. federal income tax purposes, the Managing General Partner may elect to treat the Partnership as an association or as a publicly traded partnership taxable as a corporation for U.S. federal (and applicable state) income tax purposes.
Appears in 11 contracts
Samples: Limited Partnership Agreement (Brookfield Business Partners L.P.), Limited Partnership Agreement, Limited Partnership Agreement (Brookfield Infrastructure Partners L.P.)
Election to be Treated as a Corporation. Notwithstanding anything to the contrary contained herein, if If the General Partner determines in its sole discretion that it is no longer in the best interests of the Partnership to continue as a partnership for U.S. federal income tax purposes, the General Partner may elect to treat the Partnership as an association or as a publicly traded partnership taxable as a corporation for U.S. federal (and applicable state) income tax purposespurposes or may effect such change by merger or conversion or otherwise under applicable law.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Carlyle Group L.P.), Limited Partnership Agreement (Ares Management Lp), Limited Partnership Agreement (Carlyle Group L.P.)
Election to be Treated as a Corporation. β Notwithstanding anything to the contrary contained herein, if the General Partner determines in its sole discretion that it is no longer in the best interests of the Partnership to continue as a partnership for U.S. federal income tax purposes, the General Partner may elect to treat the Partnership as an association or as a publicly traded partnership taxable as a corporation for U.S. federal (and applicable state) income tax purposes.
Appears in 2 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement
