Payee Allocation. If any payment to any person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 55 contracts
Samples: Limited Partnership Agreement (New Mountain Net Lease Trust), Limited Partnership Agreement (Brookfield Real Estate Income Trust Inc.), Limited Partnership Agreement (IPC Alternative Real Estate Income Trust, Inc.)
Payee Allocation. If In the event any payment to any person Person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 9 contracts
Samples: Limited Partnership Agreement (Blackstone Infrastructure Strategies L.P.), Limited Partnership Agreement (Blackstone Infrastructure Strategies L.P.), Limited Partnership Agreement (Blackstone Private Equity Strategies Fund L.P.)
Payee Allocation. If In the event any payment to any person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partnerPartner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 4 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (Evercore Partners Inc.), Limited Partnership Agreement (Evercore Partners Inc.)
Payee Allocation. If any payment to any person Person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partnerPartner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 2 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement
Payee Allocation. If In the event that any payment to any person Person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 1 contract
Samples: Limited Partnership Agreement (CDL Tender Fund 2022-1, L.P.)
Payee Allocation. If any payment to any person that is treated by the Partnership as the payment of an expense is recharacterized by a taxing authority as a Partnership distribution to the payee as a partner, such payee shall be specially allocated, in the manner determined by the General Partner, allocated an amount of Partnership gross income and gain as quickly as possible equal to the amount of the distribution.
Appears in 1 contract
Samples: Limited Partnership Agreement (JER Investors Trust Inc)
