Opinions Regarding Taxation. Notwithstanding any other provision of this Agreement, the requirement, as a condition to any action proposed to be taken under this Agreement, that the Partnership be furnished an opinion of counsel for the Partnership to the effect that the proposed transaction would not result in the Partnership being treated as an association taxable as a corporation for federal income tax purposes, shall not be applicable if the Partnership is at such time treated in all material respects as an association taxable as a corporation for federal income tax purposes.
Appears in 2 contracts
Samples: Quarterly Report, Limited Partnership Agreement (Icahn Enterprises Holdings L.P.)
Opinions Regarding Taxation. Notwithstanding In the event that the tax status of the Partnership changes and, notwithstanding any other provision of this Agreement, the requirement, as a condition to 41 42 any action proposed to be taken under this Agreement, that the Partnership be furnished an opinion of counsel for the Partnership to the effect that the proposed transaction would not result in the Partnership being treated as an association taxable as a corporation for federal income tax purposes, shall not be applicable if the Partnership is at such time treated in all material respects as an association taxable as a corporation for federal income tax purposes.
Appears in 1 contract
Samples: Agreement of Limited Partnership (Carey Diversified Properties LLC)
Opinions Regarding Taxation. Notwithstanding In the event that the tax status of the Partnership changes and, notwithstanding any other provision of this Agreement, the requirement, as a condition to any action proposed to be taken under this Agreement, that the Partnership be furnished an opinion of counsel for the Partnership to the effect that the proposed transaction would not result in the Partnership being treated as an association taxable as a corporation for federal income tax purposes, shall not be applicable if the Partnership is at such time treated in all material respects as an association taxable as a corporation for federal income tax purposes.such
Appears in 1 contract
Samples: Agreement of Limited Partnership (Carey Diversified Properties LLC)