Common use of Substantial Economic Effect Clause in Contracts

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partnership and the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 IV and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss Loss, under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit net profit and Loss net loss (and items thereof) under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss (and other items of income, gain, loss or deduction) under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Operating Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit under Sections 5.1(a), 5.1(b), 5.1(c) and Loss under this Agreement 5.1(g) have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under pursuant to this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit net profit and Loss net loss (and items thereof), under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by and the Regulations promulgated pursuant thereto. To the greatest extent possible, Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. To the greatest extent possible, Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit Net Income, Net Loss, Net Property Gain and Net Property Loss under this the Agreement have “substantial economic effect effect” (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (effect, or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) Partnership, within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit under Sections 5.1(a), 5.1(b) and Loss under this Agreement 5.1(f) (as and when applicable) have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit Net Income and Net Loss under this the Agreement have “substantial economic effect effect” (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse non-recourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Current Profit and Residual Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have “substantial economic effect effect” (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit net income and Loss net loss (and items thereof) under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit Net Income and Net Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent; provided, that any required adjustment or maintenance does not have a material adverse effect on the economic interests of the Partners.

Substantial Economic Effect. It is the intent of the Partners --------------------------- that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss and items of income, gain, expense and loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant theretorelated Regulations. Article 5 6 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such that intent.

Substantial Economic Effect. It is the intent of the Partners that the --------------------------- allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners Members that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the PartnersMembers’ interests in the Partnership Company in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. This Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.intent.‌

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 Exhibit B hereto and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 . Section 5.1 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Code Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.. 19

Substantial Economic Effect. It is the intent of the Partners that the --------------------------- allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse no recourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that --------------------------- the allocations of Profit and Loss Los under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.. 24006714184-v11 - 24 - 80-41019056

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant theretorelated Regulations. Article 5 6 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such that intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit under Sections 5.01(a), (b) and Loss under this Agreement (c) have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b704 (b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.. ARTICLE

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 Exhibit B hereto and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse non-recourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit Net Income and Loss Net Losses under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. This Article 5 VI and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. This Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners Members that the allocations of Profit profit and Loss loss under this Agreement have substantial economic effect (or be consistent with the Partners’ Members' interests in the Partnership Company in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Treasury Regulations promulgated pursuant thereto. Article 5 VI and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that --------------------------- the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners Members that the allocations of Profit Net Income and Loss Net Losses under this Agreement have substantial economic effect (or be consistent with the PartnersMembers’ interests in the Partnership LLC in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. This Article 5 VII and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit Net Income and Loss Net Losses under this Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 VI and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit Profits and Loss Losses under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partnership and the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 IV and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.. Table of Contents

Substantial Economic Effect. It is the intent of the Partners that --------------------------- the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse non-recourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners Members that the allocations of Profit and Loss under this Agreement have substantial economic effect (or be consistent with the PartnersMembers’ interests in the Partnership Company in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 ARTICLE V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ” interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit and Loss under this the Agreement have substantial economic effect (or be consistent with the Partners’ ' interests in the Partnership in the case of the allocation of losses attributable to nonrecourse non-recourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.

Substantial Economic Effect. It is the intent of the Partners that the allocations of Profit Profits and Loss Losses under this Agreement have substantial economic effect (or be consistent with the Partners’ interests in the Partnership in the case of the allocation of losses attributable to nonrecourse debt) within the meaning of Section 704(b) of the Code as interpreted by the Regulations promulgated pursuant thereto. Article 5 V and other relevant provisions of this Agreement shall be interpreted in a manner consistent with such intent.