Incorporation of Agreements. The Exchange Agreement and the Tax Receivable Agreement shall each be treated as part of this Agreement as described in Section 761(c) of the Code and Treasury Regulation Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c).
Appears in 31 contracts
Samples: Limited Partnership Agreement, Agreement of Limited Partnership, Merger Agreement (Och-Ziff Capital Management Group LLC)
Incorporation of Agreements. The Exchange Agreement and the Tax Receivable Agreement shall each be treated as part of this Agreement as described in Section 761(c761 (c) of the Code and Treasury Regulation Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c).
Appears in 1 contract
Samples: Limited Partnership Agreement (Och-Ziff Capital Management Group LLC)