Common use of Classification as a Partnership Clause in Contracts

Classification as a Partnership. The parties hereto intend that the Partnership be classified as a partnership for U.S. federal income tax purposes effective as of the date of this Agreement. The General Partner shall not elect to have the Partnership classified as an association taxable as a corporation for U.S. federal income tax purposes pursuant to Treasury Regulations Section 301.7701–3. The General Partner shall, for and on behalf of the Partnership, take all steps as may be required or advisable to maintain the Partnership’s classification as a partnership for U.S. federal income tax purposes.

Classification as a Partnership. The parties hereto intend that the Partnership shall at all times be classified as a partnership for U.S. United States federal income tax purposes effective as of the date of this Agreementand no Partner shall take any action or position inconsistent with such status. The General Partner shall not elect to have the Partnership classified as an association taxable as a corporation for U.S. United States federal income tax purposes pursuant to Treasury Regulations Section 301.7701–3301.7701-3. The General Tax Matters Partner or the Partnership Representative, as applicable, shall, for and on behalf of the Partnership, take all steps as may be required or advisable to maintain the Partnership’s classification as a partnership for U.S. federal income tax purposes.