Rights as a Unitholder. The LTIP Units shall be treated as a “profits interest” within the meaning of Revenue Procedure 93-27, and the Recipient shall be treated as having received the interest on the Grant Date as contemplated under Section 4 of Revenue Procedure 2001-43. As the owner of the LTIP Units for income tax purposes, the Recipient shall take into account the Recipient’s distributive share of income, gain, loss, deduction and credit associated with the LTIP Units as determined in accordance with the terms of the Limited Partnership Agreement and this Agreement.
Appears in 2 contracts
Sources: Performance Ltip Units Agreement (Omega Healthcare Investors Inc), Performance Ltip Unit Agreement (Omega Healthcare Investors Inc)