Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L, if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.7 or otherwise 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’ Capital Accounts.
Appears in 12 contracts
Samples: Limited Partnership Agreement (Paramount Group, Inc.), Limited Partnership Agreement (Gaming & Leisure Properties, Inc.), Limited Partnership Agreement (Paramount Group, Inc.)
Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L6.1E, if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.7 or otherwise is determined for U.S. federal income tax purposes not to constitute a payment of expenses of to 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 (Cole Real Estate Income Strategy (Daily Nav), Inc.), Limited Partnership Agreement (Cole Real Estate Income Strategy (Daily Nav), Inc.), Limited Partnership Agreement (Cole Real Estate Income Strategy (Daily Nav), Inc.)
Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L, if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.4B, Section 7.7 or otherwise 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’ Capital Accounts.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Park View OZ REIT Inc), Agreement of Limited Partnership (1st stREIT Office Inc.)
Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L6.1(l), if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.7 or otherwise 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’ Capital Accounts.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Curbline Properties Corp.), Limited Partnership Agreement (Curbline Properties Corp.)
Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L6.1G, if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.7 7.3A, Section 7.6 or otherwise 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’ Capital Accounts.
Appears in 1 contract
Samples: Limited Partnership Agreement (Nico Echo Park, Benefit Corp)
Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L6.1H, if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.7 7.3A, Section 7.6 or otherwise 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’ Capital Accounts.
Appears in 1 contract
Samples: Agreement of Limited Partnership (Platform Ventures Diversified Housing REIT, LLC)
Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L6.1J, if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.7 or otherwise is determined for U.S. federal income tax purposes not to constitute a payment of expenses of to 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 1 contract
Samples: Limited Partnership Agreement (Cole Real Estate Income Strategy (Daily Nav), Inc.)
Reimbursements Treated as Guaranteed Payments. Subject to Section 6.1L, if and to the extent any payment or reimbursement to the General Partner or the Company made pursuant to Section 7.7 or otherwise 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’ Capital Accounts.
Appears in 1 contract
Samples: Agreement of Limited Partnership (Hertz Group Realty Trust, Inc.)