3
Shared Docs
3
Same-Page
3 / 3
Mentions
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
n 6.1 unless the Seller has received a bona fide written offer (the "Purchase Offer") from the prospective transferee (the "Purchaser") to purchase the Offered Interests for a purchase price (the "Offer Price") denominated and payable in United States dollars at closing or according to specified terms, with or witho
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
n 6.1 unless the Seller has received a bona fide written offer (the "Purchase Offer") from the prospective transferee (the "Purchaser") to purchase the Offered Interests for a purchase price (the "Offer Price") denominated and payable in United States dollars at closing or according to specified terms, with or witho
) of the Code and the Treasury Regulations promulgated thereunder so as to take account of any difference between the tax basis of such property to the Partnership for Federal income tax purposes and its book basis. 4.1.3 If any Partnership Interest is transferred or any Percentage Interest is changed pursuant to the term
n 6.1 unless the Seller has received a bona fide written offer (the "Purchase Offer") from the prospective transferee (the "Purchaser") to purchase the Offered Interests for a purchase price (the "Offer Price") denominated and payable in United States dollars at closing or according to specified terms, with or witho
Entities connected to both the Partnership for Federal and the Offered Interests
Accounting Period
ORGANIZATIONReliance
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONFederal, State
ORGANIZATIONthe Person or Persons
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONLeon Black
PERSONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONPurchase
LOCATIONAllocation of Profits
ORGANIZATIONthe United States Treasury
LOCATIONNet Profit
ORGANIZATIONNet Profit and Net Loss
ORGANIZATIONCertificate of Formation
ORGANIZATIONWithdrawing Partner
PERSON
Wilmington
LOCATIONElysium Management LLC
ORGANIZATIONCorporation Services Company
ORGANIZATION