Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner a single capital account combining such Partner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner determines are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 28 contracts
Samples: Limited Partnership Agreement (Blackstone Inc.), Limited Partnership Agreement (Blackstone Inc.), Limited Partnership Agreement (Blackstone Group Inc)
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner Member a single capital account combining such PartnerMember’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner Managing Member determines are is appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 22 contracts
Samples: Limited Liability Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement (Blackstone Group L.P.)
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal Federal income tax purposes, there shall be established for each Partner a single capital account combining such Partner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner determines are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 8 contracts
Samples: Blackstone Inc., Blackstone Group Inc, Blackstone Group Inc
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner a single capital account combining such Partner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner determines are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 7 contracts
Samples: Agreement (Blackstone Group Inc), Highly (Blackstone Group L.P.), Blackstone Group L.P.
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner Member a single capital account combining such PartnerMember’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner Managing Member determines are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.)
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal Federal income tax purposes, there shall be established for each Partner Member a single capital account combining such PartnerMember’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner Managing Member determines are is appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.), Limited Liability Company Agreement (Blackstone Group L.P.)
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner a single capital account combining such Partner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner determines are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 3 contracts
Samples: Blackstone Group L.P., Blackstone Group L.P., Blackstone Group L.P.
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner a single capital account combining such Partner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner determines are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 2 contracts
Samples: Blackstone Real Estate Special (Blackstone Group L.P.), Blackstone Group L.P.
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner a single capital account combining such Partner’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner Delaware GP determines are is appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 1 contract
Samples: Blackstone Group L.P.
Tax Capital Accounts; Tax Allocations. (a) For U.S. federal income tax purposes, there shall be established for each Partner Member a single capital account combining such PartnerMember’s Capital Commitment Capital Account and GP-Related Capital Account, with such adjustments as the General Partner Managing Member determines are appropriate so that such single capital account is maintained in compliance with the principles and requirements of Section 704(b) of the Code and the Treasury Regulations thereunder.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Blackstone Group Inc)