Following the Exercise Date, each of the parties hereto shall, and shall cause their respective Affiliates to, execute and deliver such additional documents, instruments, conveyances and assurances and take such further actions as may be reasonably required to carry out the provisions hereof and give effect to the transactions contemplated by this Agreement (including any actions necessary to admit Holdings as a partner of Rhino effective as of the issuance of the Call Option Premium Units). The parties hereto agree that to the extent the issuance of the Rhino GP LLC Interest by Rhino GP would result in a more favorable tax treatment to Holdings, the parties will negotiate in good faith to effectuate an issuance of the Rhino GP LLC Interest rather than a transfer of such interest from Royal.