Common use of Partnership Division Clause in Contracts

Partnership Division. In a series of transactions that comprised an “assets over” partnership division described in Treasury Regulation Section 1.708-1(d), OZ Advisors II LP succeeded to certain assets of the Partnership, including goodwill and other intangible assets. In that partnership division, the Partnership was the “prior partnership”/“divided partnership” and OZ Advisors II LP was the “recipient partnership.” The Partnership will file its federal, state, and local tax returns consistent with that characterization. Terms in quotations in this Section 4.6(e) have the meanings given thereto in Treasury Regulation Sections 1.708-1(d)(3) and (d)(4).

Partnership Division. In a series of transactions that comprised an “assets over” partnership division described in Treasury Regulation Section 1.708-1(d), OZ Advisors II LP the Partnership succeeded to certain assets of the PartnershipOZ Management LP, including goodwill and other intangible assets. In that partnership division, the Partnership was the “prior partnership”/“divided recipient partnership” and OZ Advisors II Management LP was the “recipient prior partnership”/“divided partnership.” The Partnership will file its federal, state, and local tax returns consistent with that characterization. Terms in quotations in this Section 4.6(e) have the meanings given thereto in Treasury Regulation Sections 1.708-1(d)(3) and (d)(4).

Partnership Division. In a series of transactions that comprised an “assets over” partnership division described in Treasury Regulation Section 1.708-1(d), OZ Advisors II LP the Partnership succeeded to certain assets of the PartnershipOZ Management LP, including goodwill and other intangible assets. In that partnership division, the Partnership was the “prior partnership”/“divided recipient partnership” and OZ Advisors II Management LP was the “recipient prior partnership”/”divided partnership.” The Partnership will file its federal, state, and local tax returns consistent with that characterization. Terms in quotations in this Section 4.6(e) have the meanings given thereto in Treasury Regulation Sections 1.708-1(d)(3) and (d)(4).