Pre-Exchange Transfer definition

Pre-Exchange Transfer means any transfer or distribution in respect of one or more Common Units (i) that occurs prior to an Exchange of such Common Units, and (ii) to which Section 743(b) or 734(b) of the Code applies.

Pre-Exchange Transfer means any transfer of one or more Units (including upon the death of a TRA Holder) (i) that occurs after the IPO but prior to an Exchange of such Units and (ii) to which Section 743(b) of the Code applies.

Pre-Exchange Transfer means, with respect to an LLC Unit, any transfer (including upon the death of an LLC Unit Holder) (i) that occurs prior to an Exchange of such LLC Unit or LLC Units and (ii) to which Section 743(b) of the Code applies.

Examples of Pre-Exchange Transfer in a sentence

• Notwithstanding any other provision of this Agreement, the amount of any Basis Adjustment or Section 704(c) Allocation Amount resulting from an Exchange of one or more Common Units is to be determined as if any Pre-Exchange Transfer of such Common Units had not occurred.

• The proposed order does not require that El Paso present the Commission with a buyer of the assets to be divested before acceptance of the proposed consent agreement for public comment (an "up-front buyer") because El Paso has satisfied the Commission that, in this instance, consumers will not be harmed by a post-order divestiture.

• Notwithstanding any other provision of this Agreement, the amount of any Basis Adjustment resulting from the CF OMS Sale, an Exchange of one or more Common Units or Earnout Units shall be determined without regard to any Pre-Exchange Transfer of such Common Units and as if any such Pre-Exchange Transfer had not occurred.

• For the avoidance of doubt, the amount of any Basis Adjustment resulting from an Exchange of one or more Units shall be determined without regard to any Pre-Exchange Transfer of such Units and as if any such Pre-Exchange Transfer had not occurred.

• Notwithstanding any other provision of this Agreement, the amount of any Exchange Party Basis Adjustment resulting from an Exchange of one or more Company Units shall be determined without regard to any Pre-Exchange Transfer of such Units and as if any such Pre-Exchange Transfer had not occurred.

More Definitions of Pre-Exchange Transfer

Pre-Exchange Transfer means any transfer of one or more Partnership Interests (i) that occurs prior to an Exchange of such Partnership Interests, and (ii) to which Section 743(b) applies.

Pre-Exchange Transfer means any transfer (including upon the death of a Limited Partner) of one or more OCGH Units (i) that occurs prior to an Exchange of such OCGH Units, and (ii) to which Section 734(b) or 743(b) of the Code applies.

Pre-Exchange Transfer means any transfer (including upon death of an LP Unit Holder) or distribution in respect of one or more LP Units (i) that occurs prior to an Exchange of such LP Unit or LP Units and (ii) to which Section 743(b) or 734(b) of the Code applies.

Pre-Exchange Transfer means any transfer (including upon the death of a Member) of one or more Class B Exchangeable Units (i) that occurs prior to an Exchange of such Class B Exchangeable Units, and (ii) to which Section 743(b) of the Code applies.

Pre-Exchange Transfer means any transfer (or deemed transfer) of one or more Units (i) that occurs after the consummation of the IPO but prior to an Exchange of such Units and (ii) to which Section 743(b) of the Code applies, excluding the IPO Unit Redemption.

Pre-Exchange Transfer means any transfer of one or more RTEA Units that occurs prior to an Exchange of such RTEA Units.

Pre-Exchange Transfer means any transfer (including upon the death of a Seller) or distribution in respect of one or more Exchangeable Interests (a) that occurs prior to an Exchange of such Exchangeable Interests, and (b) to which Section 743(b) or 734(b) of the Code applies.