Common use of Possible Additional Restrictions on Transfer Clause in Contracts

Possible Additional Restrictions on Transfer. Notwithstanding anything to the contrary contained in this Agreement, in the event of (i) the enactment (or imminent enactment) of any legislation, (ii) the publication of any temporary or final Regulations, (iii) any ruling by the Internal Revenue Service or (iv) any judicial decision that in any such case, in the opinion of counsel, would result in the taxation of the Partnership for federal income tax purposes as a corporation or would otherwise subject the Partnership to being taxed as an entity other than a partnership for federal income tax purposes, this Agreement shall be deemed to impose such restrictions on the transfer of a Partner’s Interest as may be required, in the opinion of counsel to the Partnership, to prevent the Partnership from being taxed as a corporation or otherwise being taxed as an entity other than a partnership for federal income tax purposes, and the Partners thereafter shall amend this Agreement as necessary or appropriate to impose such restrictions.

Possible Additional Restrictions on Transfer. Notwithstanding anything to the contrary contained in this Agreement, in the event of (ia) the enactment (or imminent enactment) of any legislation, (iib) the publication of any temporary or final Regulationsregulation by the Treasury Department (“Treasury Regulation”), (iiic) any ruling by the Internal Revenue Service Service, or (ivd) any judicial decision that in any such case, in the opinion of counseltax counsel to the Company, would result in the taxation of the Partnership Company for federal income tax purposes as a corporation or would otherwise subject the Partnership Company to being taxed as an entity other than a partnership for federal income tax purposes, this Agreement shall will be deemed to impose such restrictions on the transfer Transfer of a Partner’s Partnership Interest as may be required, in the opinion of counsel to the PartnershipCompany, to prevent the Partnership Company from being taxed as a corporation or otherwise being taxed as an entity other than a partnership for federal income tax purposes, and the Partners hereby agree thereafter shall to amend this Agreement as necessary or appropriate to impose such restrictions.