Application of “Traditional Method. Notwithstanding any provision of the Partnership Agreement, the Partnership shall use the “traditional method” under Treasury Regulations Section 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code with respect to any Gain Limitation Property.
Appears in 3 contracts
Samples: Form of Tax Protection Agreement (Richmond Honan Medical Properties Inc.), Form of Tax Protection Agreement (Richmond Honan Medical Properties Inc.), Form of Tax Protection Agreement (Richmond Honan Medical Properties Inc.)
Application of “Traditional Method. Notwithstanding any provision of the Partnership AgreementAgreement to the contrary, the Partnership shall use the “traditional method” under Treasury Regulations Section 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code with respect to any Gain Limitation Propertythe Protected Properties.
Appears in 2 contracts
Samples: Tax Protection Agreement (Farmland Partners Inc.), Tax Protection Agreement (Farmland Partners Inc.)
Application of “Traditional Method. Notwithstanding any provision of the Partnership Agreement, the Partnership shall use the “"traditional method” " under Treasury Regulations Section § 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code (with respect no "curative allocations" to offset the effects of the "ceiling rule," including upon any sale of a Protected Property or Gain Limitation Property).
Appears in 1 contract
Application of “Traditional Method. Notwithstanding any provision of the Partnership Agreement, the Partnership shall use the “traditional method” under Treasury Regulations Regulation Section 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code with respect to the Protected Properties (with no “curative allocation” to offset the effects of the “ceiling rule,” including upon any Gain Limitation sale of a Protected Property.). ARTICLE VI
Appears in 1 contract
Samples: Form of Tax Protection Agreement (DLC Realty Trust, Inc.)
Application of “Traditional Method. Notwithstanding any provision of the Partnership Agreementoperating agreement of the Partnership, the Partnership shall use the “traditional method” under Treasury Regulations Section 1.704-3(b) (with no “curative allocations”) for purposes of making all allocations under Section 704(c) of the Code with respect to any Gain Limitation Propertythe Protected Interest.
Appears in 1 contract
Samples: Tax Protection Agreement (Pennsylvania Real Estate Investment Trust)
