Common use of Provisions Relating to Tax Treatment Clause in Contracts

Provisions Relating to Tax Treatment. (a) Prior to the issuance of the Conversion Notice, the sole Beneficial Owner of the Trust shall be the Depositor. The rights of the Depositor (as the Class 2 Beneficial Owner) with respect to the assets and property held by the Trust, as provided in Section 6.11, are such that the Trust will be characterized at such time as a “business entity” within the meaning of Regulation Section 301.7701-3. Because the Depositor will be the sole Beneficial Owner, the Trust will be characterized as a disregarded entity, and all assets and property of the Trust shall be treated for Federal income tax purposes as assets and property of the Depositor.

Appears in 3 contracts

Samples: Trust Agreement (Black Creek Diversified Property Fund Inc.), Trust Agreement, Trust Agreement (Dividend Capital Diversified Property Fund Inc.)

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Provisions Relating to Tax Treatment. (a) Prior to the issuance of the Conversion Notice, the sole Beneficial Owner of the Trust shall be the Depositor. The rights of the Depositor (as the Class 2 Beneficial Owner) with respect to the assets and property held by the Trust, as provided in Section 6.116.11 hereof, are such that the Trust will be characterized at such time as a “business entity” within the meaning of Regulation Regulations Section 301.7701-3. Because the Depositor will be the sole Beneficial Owner, the Trust will be characterized as a disregarded entity, and all assets and property of the Trust shall be treated for Federal federal income tax purposes as assets and property of the Depositor.

Appears in 1 contract

Samples: Trust Agreement (Jones Lang LaSalle Income Property Trust, Inc.)

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