Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of OpCo 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 32 contracts
Samples: Tax Receivable Agreement (European Wax Center, Inc.), Tax Receivable Agreement (Clear Secure, Inc.), Tax Receivable Agreement (Clear Secure, Inc.)
Partnership Agreement. This To the extent this Agreement imposes obligations on OpCo or a member of OpCo, this Agreement shall be treated as part of the partnership agreement of OpCo 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 (TWFG, Inc.), Tax Receivable Agreement (TWFG, Inc.)
Partnership Agreement. This Agreement shall be treated as part of the partnership agreement of OpCo 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.. Doc#: US1:14717400v22
Appears in 1 contract
Samples: Tax Receivable Agreement (European Wax Center, Inc.)
Partnership Agreement. This Agreement Agreement, to the extent it relates to holders of Common Units, shall be treated as part of the partnership agreement of OpCo 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 1 contract
Samples: Tax Receivable Agreement (Xponential Fitness, Inc.)
Partnership Agreement. This Agreement Agreement, to the extent it relates to holders of Common Units (or other membership interests), shall be treated as part of the partnership agreement of OpCo 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 1 contract
Samples: Tax Receivable Agreement (Xponential Fitness, Inc.)
Partnership Agreement. This Agreement Agreement, inasmuch as it applies to holders of Common Units, shall be treated as part of the partnership agreement of OpCo 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 1 contract
