FIC Distribution. The parties to this Agreement agree that the FIC Distribution gave rise to an adjustment to the tax basis of certain property of Opal Capital Group LLC or its successor in interest pursuant to Code Section 734. To the extent such adjustment is allocated to depreciable or amortizable property, then to the extent permitted by law the parties agree to treat such basis adjustment as a separate item of property for purposes of Code Sections 168 and 197, as applicable, that is not “Section 704(c) property” as defined in Regulations Section 1.704-3(a)(3)(i).
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Samples: Limited Partnership Agreement (Blue Owl Capital Inc.), Limited Partnership Agreement (Blue Owl Capital Inc.), Limited Partnership Agreement (Blue Owl Capital Inc.)
