Character of Liquidating Distributions. To the extent that the tax treatment of any payments or distributions to any Management Unit Holder pursuant to this Agreement is governed by Section 736 of the Code, such payments or distributions shall be treated as made in exchange for such Member’s interests in the Company’s property pursuant to Section 736(b)(1) of the Code, including the interests of such Management Unit Holder in the Company’s goodwill.
Appears in 2 contracts
Sources: Limited Liability Company Agreement, Limited Liability Company Agreement (Lazard LTD)