Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each Partnership as described in Section 761(c) of the Code, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 10 contracts
Samples: Tax Receivable Agreement (Blackstone Group Inc), Tax Receivable Agreement, Tax Receivable Agreement
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each Partnership LLC Agreement as described in Section 761(c) of the Code, Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 5 contracts
Samples: Tax Receivable Agreement (Rani Therapeutics Holdings, Inc.), Tax Receivable Agreement (Direct Digital Holdings, Inc.), Tax Receivable Agreement (Dutch Bros Inc.)
Partnership Agreement. This To the extent this Agreement imposes obligations upon a particular Partnership or a general partner of a Partnership, this Agreement shall be treated as part of the relevant partnership agreement of each Partnership as described in Section 761(c) of the Code, Code and Sections sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 4 contracts
Samples: Tax Receivable Agreement, Tax Receivable Agreement (Och-Ziff Capital Management Group LLC), Tax Receivable Agreement (Och-Ziff Capital Management Group LLC)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each Partnership Holding as described in Section 761(c) of the Code, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 4 contracts
Samples: Tax Receivable Agreement (Vantiv, Inc.), Tax Receivable Agreement (Vantiv, Inc.), Tax Receivable Agreement (Vantiv, Inc.)
Partnership Agreement. This To the extent this Agreement imposes obligations upon the Partnership or a partner of the Partnership, this Agreement shall be treated as part of the partnership agreement of each the Partnership as described in Section section 761(c) of the Code, Code and Sections sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 4 contracts
Samples: Tax Receivable Agreement (Moelis & Co), Tax Receivable Agreement (Moelis & Co), Tax Receivable Agreement (Moelis & Co)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each Partnership Agreement as described in Section 761(c) of the Code, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 3 contracts
Samples: Income Tax Receivable Agreement, Income Tax Receivable Agreement (Graham Packaging Co Inc.), Income Tax Receivable Agreement (Graham Packaging Co Inc.)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each the Partnership as described in Section 761(c) of the CodeInternal Revenue Code of 1986, as amended, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 3 contracts
Samples: Tax Receivable Agreement (Virgin Mobile USA, Inc.), Tax Receivable Agreement (Virgin Mobile USA, Inc.), Tax Receivable Agreement (Virgin Mobile USA, Inc.)
Partnership Agreement. This To the extent applicable, this Agreement shall be treated as part of the partnership agreement of each Partnership Holdings as described in Section 761(c) of the Code, Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 2 contracts
Samples: Tax Receivable Agreement (Golden Nugget Online Gaming, Inc.), Tax Receivable Agreement (Silver Run Acquisition Corp II)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each the Partnership as described in Section 761(c) of the Code, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 2 contracts
Samples: Tax Receivable Agreement (PJT Partners Inc.), Tax Receivable Agreement (PJT Partners Inc.)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each Partnership as described in Section 761(c) of the CodeInternal Revenue Code of 1986, as amended, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 2 contracts
Samples: Tax Receivable Agreement (Fortress Investment Group LLC), Tax Receivable Agreement (Fortress Investment Group Holdings LLC)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each Partnership as described in Section 761(c) of the Code, Code and Sections sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 1 contract
Samples: Tax Receivable Agreement (Och-Ziff Capital Management Group LLC)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of each Partnership Agreement as described in Section 761(c) of the Code, Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 1 contract
