Common use of No Transfers Affecting Tax Status of Partnership Clause in Contracts

No Transfers Affecting Tax Status of Partnership. No transfer of Partnership Units by a Limited Partner may be made to any Person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation for federal income tax purposes, (ii) in the opinion of legal counsel for the Partnership, it would adversely affect the ability of CarrAmerica to continue to qualify as a REIT or would subject CarrAmerica to any additional taxes under Section 857 or Section 4981 of the Code, or (iii) such transfer is attempted to be effectuated through an "established securities market" or a "secondary market (or the substantial equivalent thereof)" within the meaning of Section 7704 of the Code.

No Transfers Affecting Tax Status of Partnership. No transfer of Partnership Units by a Limited Partner may be made to any Person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation for federal income tax purposes or would result in a termination of the Partnership for federal income tax purposes, (ii) in the opinion of legal counsel for the Partnership, it would adversely affect the ability of CarrAmerica the General Partner Entity to continue to qualify as a REIT or would subject CarrAmerica the General Partner Entity to any additional taxes under Section 857 or Section 4981 of the Code, Code or (iii) such transfer is attempted to be effectuated through an "established securities market" or a "secondary market (or the substantial equivalent thereof)" within the meaning of Section 7704 of the Code.

No Transfers Affecting Tax Status of Partnership. No transfer of Partnership Units by a Limited Partner (including a redemption or exchange pursuant to Section 8.6 hereof) may be made to any Person if (i) in the opinion of legal counsel for the Partnership, it would result in the Partnership being treated as an association taxable as a corporation for federal income tax purposes or would result in a termination of the Partnership for federal income tax purposes, (ii) in the opinion of legal counsel for the Partnership, it would adversely affect the ability of CarrAmerica the Company to continue to qualify as a REIT or would subject CarrAmerica the Company to any additional taxes under Section 857 or Section 4981 of the Code, Code or (iii) such transfer is attempted to be effectuated through an "“established securities market" ” or a "“secondary market (or the substantial equivalent thereof)" ” within the meaning of Section 7704 of the Code.