Tax Controversies. Subject to the provisions hereof, the General Partner shall designate the Organizational Limited Partner or such other Partner as the General Partner shall determine as the “tax matters partner” (as defined in Section 6231(a)(7) of the Code) (the “Tax Matters Partner”), and such Person is authorized and required to represent the Partnership (at the Partnership’s expense) in connection with all examinations of the Partnership’s affairs by tax authorities, including resulting administrative and judicial proceedings, and to expend Partnership funds for professional services and costs associated therewith. Each Partner agrees to cooperate with the Tax Matters Partner and to do or refrain from doing any or all things reasonably required by the Tax Matters Partner to conduct such proceedings.
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Samples: Agreement, Partnership Agreement (CONSOL Coal Resources LP), Partnership Agreement (CNX Coal Resources LP)
Tax Controversies. Subject to the provisions hereof, the Managing General Partner shall designate is designated the Organizational Limited Tax Matters Partner or such other Partner as the General Partner shall determine as the “tax matters partner” (as defined in Section 6231(a)(7) 6231 of the Code) (and the “designated partner for the purposes of the Income Tax Matters Partner”)Act including subsections 152(1.4) to 152(1.8) thereof, and such Person is authorized and required to represent the Partnership (at the Partnership’s expense) in connection with all examinations of the Partnership’s affairs by tax authorities, including resulting administrative and judicial proceedings, and to expend Partnership funds for professional services and costs associated therewith. Each Partner agrees to cooperate with the Tax Matters Managing General Partner and to do or refrain from doing any or all things reasonably required by the Tax Matters Managing General Partner to conduct such proceedings.
Appears in 7 contracts
Samples: Agreement (Brookfield Infrastructure Partners L.P.), Agreement (Brookfield Infrastructure Partners L.P.), Agreement (Brookfield Infrastructure Partners L.P.)
Tax Controversies. Subject to the provisions hereof, the General Partner shall designate is designated the Organizational Limited Tax Matters Partner or such other Partner as the General Partner shall determine as the “tax matters partner” (as defined in Section 6231(a)(7) 6231 of the Code) (and the “designated partner for the purposes of the Income Tax Matters Partner”)Act including subsections 152(1.4) to 152(1.8) thereof, and such Person is authorized and required to represent the Partnership (at the Partnership’s expense) in connection with all examinations of the Partnership’s affairs by tax authorities, including resulting administrative and judicial proceedings, and to expend Partnership funds for professional services and costs associated therewith. Each Partner agrees to cooperate with the Tax Matters General Partner and to do or refrain from doing any or all things reasonably required by the Tax Matters General Partner to conduct such proceedings.
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Tax Controversies. Subject to the provisions hereof, the General Partner shall designate is designated the Organizational Limited Tax Matters Partner or such other Partner as the General Partner shall determine as the “tax matters partner” (as defined in Section 6231(a)(7) 6231 of the Code) (), shall have all the “powers and duties assigned to a Tax Matters Partner”), Partner under Sections 6221-6232 of the Code and such Person Treasury Regulations thereunder and further is authorized and required to represent the Partnership (at the Partnership’s 's expense) in connection with all examinations of the Partnership’s 's affairs by tax authorities, including resulting administrative and judicial proceedings, and to expend Partnership funds for professional services and costs associated therewith. Each Partner agrees to cooperate with the Tax Matters General Partner and to do or refrain from doing any or all things reasonably required by the Tax Matters General Partner to conduct such proceedings.
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Samples: FFP Real Estate Trust
Tax Controversies. Subject to the provisions hereof, the General Partner shall designate is designated the Organizational Limited Tax Matters Partner or such other Partner as the General Partner shall determine as the “tax matters partner” (as defined in Section 6231(a)(7) 6231 of the Code) (and the “designated partner for the purposes of the Income Tax Matters Partner”)Act including subsections 152(1.4) to 152(1.8) thereof, and such Person is authorized and required to represent the Partnership (at the Partnership’s expense) in connection with all examinations of the Partnership’s affairs by tax authorities, including resulting [A&R LP AGR_BRELP] administrative and judicial proceedings, and to expend Partnership funds for professional services and costs associated therewith. Each Partner agrees to cooperate with the Tax Matters General Partner and to do or refrain from doing any or all things reasonably required by the Tax Matters General Partner to conduct such proceedings.
Appears in 1 contract
Samples: Agreement (Brookfield Renewable Energy Partners L.P.)
Tax Controversies. Subject to the provisions hereof, the General Partner shall designate is designated the Organizational Limited Tax Matters Partner or such other Partner as the General Partner shall determine as the “tax matters partner” (as defined in Section 6231(a)(7) 6231 of the Code) and the designated partner for the purposes of the Income Tax Act including subsections 152(1.4) to 152 (the “Tax Matters Partner”)1.8) thereof, and such Person is authorized and required to represent the Partnership (at the Partnership’s expense) in connection with all examinations of the Partnership’s affairs by tax authorities, including resulting administrative and judicial proceedings, and to expend Partnership funds for professional services and costs associated therewith. Each Partner agrees to cooperate with the Tax Matters General Partner and to do or refrain from doing any or all things reasonably required by the Tax Matters General Partner to conduct such proceedings.
Appears in 1 contract
Samples: Agreement (Brookfield Infrastructure Partners L.P.)
Tax Controversies. Subject to the provisions hereof, the General Partner shall designate is designated the Organizational Limited Tax Matters Partner or such other Partner as the General Partner shall determine as the “tax matters partner” (as defined in Section 6231(a)(7) 6231 of the Code) (and the “designated partner for the purposes of the Income Tax Matters Partner”)Act including subsections 152(1.4) to 152(1.8) thereof, and such Person is authorized and required to represent the Partnership (at the Partnership’s 's expense) in connection with all examinations of the Partnership’s 's affairs by tax authorities, including resulting administrative and judicial proceedings, and to expend Partnership funds for professional services and costs associated therewith. Each Partner agrees to cooperate with the Tax Matters General Partner and to do or refrain from doing any or all things reasonably required by the Tax Matters General Partner to conduct such proceedings.
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