MLP Status. The Partnership is properly treated as a partnership for United States federal income tax purposes and has, for each taxable year beginning after December 31, 2010 during which the Partnership was in existence, met the gross income requirements of Section 7704(c)(2) of the Code.
Appears in 3 contracts
Samples: Common Unit Purchase Agreement, Purchase Agreement (CSI Compressco LP), Common Unit Purchase Agreement (Rose Rock Midstream, L.P.)
MLP Status. The For the current taxable year and each taxable year during which the Partnership has been in existence, the Partnership is and has been properly treated as a partnership for United States federal income tax purposes and has, for each taxable year beginning after December 31, 2010 during which the Partnership was in existence, met the gross income requirements of Section 7704(c)(2) 7704 of the CodeInternal Revenue Code and the regulations promulgated thereunder from time to time by the U.S. Department of the Treasury.
Appears in 2 contracts
Samples: Purchase Agreement (NGL Energy Partners LP), Purchase Agreement (NGL Energy Partners LP)
MLP Status. The Partnership is and has been (for each taxable year during which it has been in existence) properly treated as a partnership for United States federal income tax purposes purposes. More than 90% of the Partnership’s gross income is and has, has been (for each taxable year beginning after December 31, 2010 during which the Partnership was it has been in existence, met the gross existence as a master limited partnership) qualifying income requirements of under Section 7704(c)(27704(d) of the Code.
Appears in 2 contracts
Samples: Series a Preferred Unit Purchase Agreement (Rhino Resource Partners LP), Series a Preferred Unit Purchase Agreement (Royal Energy Resources, Inc.)
MLP Status. The Partnership is properly treated as a partnership for United States federal income tax purposes and has, for each taxable year beginning after December 31, 2010 during which the Partnership was in existence, met the gross income requirements of Section 7704(c)(2) of the Internal Revenue Code.
Appears in 2 contracts
Samples: Purchase Agreement (NGL Energy Partners LP), Common Unit Purchase Agreement (NGL Energy Partners LP)
MLP Status. The Partnership is properly treated as a partnership for United States federal income tax purposes and has, for each taxable year beginning after December 31, 2010 2011 during which the Partnership was in existence, met the gross income requirements of Section 7704(c)(2) of the Internal Revenue Code. The Partnership expects to meet the gross income requirements of Section 7704(c)(2) of the Code for its taxable year ending December 31, 2017.
Appears in 1 contract
Samples: Registration Rights Agreement (Mid-Con Energy Partners, LP)
MLP Status. The Partnership is is, and has been since its formation, properly treated as a partnership classified for United States U.S. federal income tax purposes as a partnership or an entity disregarded as separate from its owner in accordance with Treasury Regulation Section 301.7701-3. For the taxable year including the Partnership’s initial public offering and has, for each taxable year beginning after December 31thereafter, 2010 during which the Partnership was in existence, has met the gross income requirements of Section 7704(c)(2) of the Code, and otherwise satisfied the requirements for treatment as a partnership for United States federal income tax purposes. The Partnership expects to meet these requirements for its current taxable year.
Appears in 1 contract
Samples: Contribution Agreement (Mid-Con Energy Partners, LP)
MLP Status. The Partnership is properly treated as a partnership for United States federal income tax purposes and has, for each taxable year beginning after December 31, 2010 2011 during which the Partnership was in existence, met the gross income requirements of Section 7704(c)(2) of the Internal Revenue Code. The Partnership expects to meet the gross income requirements of Section 7704(c)(2) of the Code for its taxable year ending December 31, 2018.
Appears in 1 contract
Samples: Convertible Preferred Unit Purchase Agreement (Mid-Con Energy Partners, LP)