REIT Distribution Requirements. For so long as the General Partner is taxable as a REIT, the General Partner shall use commercially reasonable efforts to cause the Partnership to distribute to all Partners pro rata in accordance with their Total Percentage Interests in amounts sufficient to enable the General Partner to (a) meet its distribution requirement for qualification as a REIT as set forth in Section 857 of the Code and (b) avoid any federal income or excise tax liability imposed by the Code, other than to the extent the General Partner elects to retain and pay income tax on its net capital gain.
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Samples: Limited Partnership Agreement (Ares Management Lp), Limited Partnership Agreement (Ares Management Lp)
REIT Distribution Requirements. For so long as the General Partner is taxable as a REIT, the The General Partner shall use commercially reasonable efforts efforts, as determined by it in its sole and absolute discretion, to cause the Partnership to distribute to all Partners pro rata in accordance with their Total Percentage Interests in amounts sufficient to enable the General Partner to pay distributions to its stockholders that will allow the General Partner to (ai) meet its distribution requirement for qualification as a REIT as set forth in Section 857 of the Code and (bii) avoid any federal income or excise tax liability imposed by the Code, other than to the extent the General Partner elects to retain and pay income tax on its net capital gain.
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Samples: Limited Partnership Agreement (Cherry Hill Mortgage Investment Corp)
REIT Distribution Requirements. For so long as the General Partner is taxable as a REIT, the The General Partner shall use commercially its reasonable efforts to cause the Partnership to distribute to all Partners pro rata in accordance with their Total Percentage Interests in amounts sufficient to enable the General Partner to pay shareholder dividends that will allow the General Partner to (ai) meet its distribution requirement for qualification as a REIT as set forth in Section 857 of the Code and (bii) avoid any federal income or excise tax liability imposed by the CodeCode or any provision of state or local law, other than to the extent the General Partner elects to retain and pay income tax on its net capital gain.
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Samples: Limited Partnership Agreement (First Potomac Realty Trust)