UBTI. The General Partner shall not enter into any transaction as a result of which a Partners will realize "unrelated business taxable income" (within the meaning of Code Section 512) ("UBTI") unless the existence of such UBTI was disclosed in writing and approved by the Partners. Notwithstanding the foregoing, the Partners acknowledge that the Partnership may acquire Investments which contain a directly owned parking garage which produces UBTI, in which event General Partner shall use its best efforts to restructure the ownership of the parking garage to eliminate any UBTI as quickly as commercially reasonable.
Appears in 2 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (Parkway Properties Inc)
UBTI. The General Partner shall not enter into any transaction as a result of which a Partners will realize "unrelated business taxable income" (within the meaning of Code Section 512512 of the Code) ("UBTI") unless the existence of such UBTI was disclosed in writing and approved by the Partners. Notwithstanding the foregoing, the Partners acknowledge that the Partnership may acquire Investments which contain a directly owned parking garage which produces UBTI, in which event General Partner shall use its best efforts to restructure the ownership of the parking garage to eliminate any UBTI as quickly as commercially reasonable.
Appears in 1 contract
Samples: Limited Partnership Agreement (Parkway Properties Inc)
UBTI. The General Partner shall not enter into any transaction as a result of which a Partners will realize "“unrelated business taxable income" ” (within the meaning of Code Section 512) ("“UBTI"”) unless the existence of such UBTI was disclosed in writing and approved by the Partners. Notwithstanding the foregoing, the Partners acknowledge that the Partnership may acquire Investments which contain a directly owned parking garage which produces UBTI, in which event General Partner shall use its best efforts to restructure the ownership of the parking garage to eliminate any UBTI as quickly as commercially reasonable.
Appears in 1 contract
Samples: Limited Partnership Agreement