Operational Rules. The General Partner, after consulting with the Partnership’s accountants or other advisers, shall determine the amount (if any) of any Tax Liability attributable to any Partner taking into account any differences in the Partners’ status, nationality or other characteristics. Any such determination regarding the amount of Tax Liability attributable to particular Partners shall be based on the manner in which the jurisdiction imposing the related tax would attribute that Tax Liability and, in making any such determination, the General Partner shall be entitled to treat any Partner as ineligible for an exemption from or reduction in rate of such tax under a tax treaty or otherwise except to the extent that such Partner provides the General Partner with such written evidence (including but not limited to forms or certificates executed by its managers and/or beneficial owners) as the General Partner or the relevant tax authorities may require to establish such Partner’s (or some or all of its beneficial owners’) entitlement to such exemption or reduction. The intent of this Section 7.4 is to ensure, to the maximum extent feasible, that the burden of any taxes withheld at the source or paid by the Partnership is borne by those Partners to which such tax obligations are attributable, and this Section 7.4 shall be interpreted and applied accordingly.
Appears in 1 contract
Sources: Limited Partnership Agreement (Plymouth Opportunity REIT Inc.)
Operational Rules. The General Partner, after consulting with the Partnership’s 's accountants or other advisers, shall determine the amount (if any) of any Tax Liability tax liability attributable to any Partner taking into account any differences in the Partners’ ' status, nationality or other characteristics. Any such determination regarding the amount of Tax Liability tax liability attributable to particular Partners shall be based on the manner in which the jurisdiction imposing the related tax would attribute that Tax Liability tax liability and, in making any such determination, the General Partner shall be entitled to treat any Partner as ineligible for an exemption from or reduction in rate of such foreign tax under a tax treaty or otherwise except to the extent that such Partner provides the General Partner with such written evidence (including but not limited to forms or certificates executed by its managers and/or beneficial owners) as the General Partner or the relevant tax authorities may require to establish such Partner’s 's (or some or all of its beneficial owners’') entitlement to such exemption or reduction. The intent of this Section 7.4 4.8(b) is to ensure, to the maximum extent feasible, that the burden of any taxes withheld at the source or paid by the Partnership is borne by those Partners to which such tax obligations are attributable, and this Section 7.4 4.8(b) shall be interpreted and applied accordingly.
Appears in 1 contract
Sources: Limited Partnership Agreement (Metropolitan Life Insurance Co/Ny)
Operational Rules. The General Partner, after consulting with the Partnership’s accountants or other advisers, shall determine the amount (if any) of any Tax Liability attributable to any Partner taking into account any differences in the Partners’ status, nationality or other characteristics. , Any such determination regarding the amount of Tax Liability attributable to particular Partners shall be based on the manner in which the jurisdiction imposing the related tax would attribute that Tax Liability and, in making any such determination, the General Partner shall be entitled to treat any Partner as ineligible for an exemption from or reduction in rate of such tax under a tax treaty or otherwise except to the extent that such Partner provides the General Partner with such written evidence (including but not limited to forms or certificates executed by its managers and/or beneficial owners) as the General Partner or the relevant tax authorities may require to establish such Partner’s (or some or all of its beneficial owners’) entitlement to such exemption or reduction. The intent of this Section 7.4 is to ensure, to the maximum extent feasible, that the burden of any taxes withheld at the source or paid by the Partnership is borne by those Partners to which such tax obligations are attributable, and this Section 7.4 shall be interpreted and applied accordingly.
Appears in 1 contract
Sources: Limited Partnership Agreement (Plymouth Opportunity REIT Inc.)