Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 is determined for federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of Section 707(c) of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution for purposes of computing the Partners' Capital Accounts.
Appears in 18 contracts
Samples: Limited Partnership Agreement (LaSalle Hotel Properties), Agreement of Limited Partnership (Presidio Golf Trust), Limited Partnership Agreement (Equity Office Properties Trust)
Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 7.04 is determined for federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of Section 707(c) of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution to the General Partner and there shall be a corresponding special allocation of gross income to the General Partner, for purposes of computing the Partners' β Capital Accounts.
Appears in 12 contracts
Samples: Limited Partnership Agreement (Gramercy Property Trust), Agreement of Limited Partnership (Gramercy Property Trust Inc.), Limited Partnership Agreement (Gramercy Property Trust Inc.)
Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 is determined for U.S. federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of Section 707(c) of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution for purposes of computing the Partners' β Capital Accounts.
Appears in 4 contracts
Samples: Agreement of Limited Partnership (InfraREIT, Inc.), Limited Partnership Agreement (InfraREIT, Inc.), Limited Partnership Agreement (InfraREIT, Inc.)
Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 7.7 is determined for federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of Section 707(c) of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution for purposes of computing the Partners' Capital Accounts.
Appears in 3 contracts
Samples: Limited Partnership Agreement (Keystone Property Trust), Limited Partnership Agreement (American Real Estate Investment Corp), Limited Partnership Agreement (American Real Estate Investment Corp)
Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 is determined for federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of Section 707(c) of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution to the General Partner and there shall be a corresponding special allocation of gross income to the General Partner, for purposes of computing the Partners' Capital Accounts.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Sl Green Realty Corp), Agreement of Limited Partnership (Sl Green Realty Corp)
Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 is determined for federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of under Section 707(c) 707 of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution for purposes of computing the Partners' Capital Accounts.
Appears in 2 contracts
Samples: Agreement of Limited Partnership (American Industrial Properties Reit Inc), Limited Partnership Agreement (American Industrial Properties Reit Inc)
Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 7.04 is determined for federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of Section 707(c) of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution to the General Partner and there shall be a corresponding special allocation of gross income to the General Partner, for purposes of computing the Partners' Capital Accounts.
Appears in 1 contract
Samples: Limited Partnership Agreement (Gramercy Capital Corp)
Reimbursement not a Distribution. If and to the extent any reimbursement made pursuant to this Section 7.4 is determined for federal income tax purposes not to constitute a payment of expenses of the Partnership, the amount so determined shall constitute a guaranteed payment with respect to capital within the meaning of Section 707(c) of the Code, shall be treated consistently therewith by the Partnership and all Partners and shall not be treated as a distribution for purposes of computing the Partners' Capital Accounts.
SECTION 7.5 OUTSIDE ACTIVITIES OF THE GENERAL PARTNERS; RELATIONSHIP OF SHARES TO PARTNERSHIP UNITS; FUNDING DEBT
Appears in 1 contract
Samples: Limited Partnership Agreement (Equity Office Properties Trust)
