Ownership in Trust. Upon any purported Transfer or Non-Transfer Event described in Section 11.7 hereof that would result in a transfer of Units to a Trust, such Units shall be deemed to have been transferred to the Trustee as trustee of a Trust for the exclusive benefit of one or more Charitable Beneficiaries. Such transfer to the Trustee shall be deemed to be effective as of the close of business on the Business Day prior to the purported Transfer or Non-Transfer Event that results in the transfer to the Trust pursuant to Section 11.7 hereof. The Trustee shall be appointed by the Company, shall be unaffiliated with the Company or a Prohibited Owner, and a “United States Person” within the meaning of 7701(a)(30) of the Code. Each Charitable Beneficiary shall be designated by the Company as provided in Section 11.7.
Appears in 5 contracts
Samples: Operating Agreement (Cardone Equal Opportunity Fund 2, LLC), Operating Agreement (Cardone Equal Opportunity Fund 2, LLC), Operating Agreement (Cardone REIT I, LLC)
