Nature as Profits Interests. (a) The Partnership and the Management Securityholder both intend that all Class B Units qualify upon issuance as “profits interests” in the Partnership within the meaning of Revenue Procedure 93-27, 1993-2 C.B. 343, or any successor Internal Revenue Service or treasury department regulation or other pronouncement applicable at the Closing Date. The Class B Units are being issued by the Partnership only for the provision of services to or for the benefit of the Partnership by the Management Securityholder and for no other consideration. The initial Capital Account of the Management Securityholder under the LP Agreement with respect to the Class B Units being granted to the Management Securityholder shall be $0. The Class B Units shall in all other respects have the attributes set forth in the LP Agreement.
Appears in 7 contracts
Samples: Management Grant Agreement (Edelman Financial Group Inc.), Management Grant Agreement (Edelman Financial Group Inc.), Management Grant Agreement (Edelman Financial Group Inc.)
