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twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Partnership by a Partner shall be allocated am
. In addition, notwithstanding Section 6.1, any interest as a Partner which is held by a custodian for a minor under a Uniform Gifts to Minors Act, Uniform Transfers to Minors Act or a similar act shall be fully transferable and assignable to the minor when the minor reaches the age of termination of such custodianship under
twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Partnership by a Partner shall be allocated am
. In addition, notwithstanding Section 6.1, any interest as a Partner which is held by a custodian for a minor under a Uniform Gifts to Minors Act, Uniform Transfers to Minors Act or a similar act shall be fully transferable and assignable to the minor when the minor reaches the age of termination of such custodianship under
twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Partnership by a Partner shall be allocated am
. In addition, notwithstanding Section 6.1, any interest as a Partner which is held by a custodian for a minor under a Uniform Gifts to Minors Act, Uniform Transfers to Minors Act or a similar act shall be fully transferable and assignable to the minor when the minor reaches the age of termination of such custodianship under
twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Company by a Member shall be allocated among t
n. In addition, notwithstanding Section 6.1, any interest as a Member which is held by a custodian for a minor under a Uniform Gifts to Minors Act, Uniform Transfers to Minors Act or a similar act shall be fully transferable and assignable to the minor when the minor reaches the age of termination of such custodianship under
Entities connected to both the Treasury Regulations and Uniform Transfers to Minors Act
the Person or Persons
ORGANIZATIONReliance
ORGANIZATIONCertificate of Formation
ORGANIZATIONFederal, State
ORGANIZATIONLeon Black
PERSONAccounting Period
ORGANIZATIONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONPurchase
LOCATIONNet Profit
ORGANIZATIONthe Offered Interests
ORGANIZATIONthe United States Treasury
LOCATIONNet Profit and Net Loss
ORGANIZATION
Wilmington
LOCATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATIONCorporation Services Company
ORGANIZATIONFirst Refusal
ORGANIZATION