Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 45 contracts
Samples: Agreement (Broad Street Realty, Inc.), FrontView REIT, Inc., FrontView REIT, Inc.
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit CC hereto, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 16 contracts
Samples: Fourth (Gramercy Property Trust Inc.), Gramercy Property Trust, Gramercy Property Trust Inc.
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit CC hereof, be characterized as Recapture Income in the same proportions and to the same extent Income, as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Incomerequired by Regulations Section 1.1245-1(e).
Appears in 13 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (JBG SMITH Properties), Limited Partnership Agreement (JBG SMITH Properties)
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit Cthis Section 6.2, be characterized as Recapture Income in the same proportions and to the same extent as such Partners (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 9 contracts
Samples: Suburban Propane Partners Lp, Suburban Propane Partners Lp, Suburban Propane Partners Lp
Recapture Income. Any gain allocated to the Partners Members upon the sale or other taxable disposition of any Partnership Company asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners Members have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Nexpoint Diversified Real Estate Trust), Limited Liability Company Agreement (Welltower OP LLC), Operating Agreement (Broadstone Net Lease, Inc.)
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit CSection 5.1(c), be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 4 contracts
Samples: Limited Partnership Agreement (OPC Residential Properties Trust, Inc.), Limited Partnership Agreement (NorthStar Real Estate Income Trust, Inc.), Limited Partnership Agreement (NorthStar Real Estate Income Trust, Inc.)
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible reasonably practicable after taking into account other required allocations of gain pursuant to Exhibit CSections 6.5 and 6.6, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 4 contracts
Samples: InfraREIT, Inc., InfraREIT, Inc., InfraREIT, Inc.
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, shall to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit EXHIBIT C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 3 contracts
Samples: Gotham Golf Corp, Gotham Golf Corp, Gotham Golf Corp
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit CSections 5.01(c) through (f), be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 3 contracts
Samples: Schedules and Exhibits (Four Springs Capital Trust), Four Springs Capital Trust, Four Springs Capital Trust
Recapture Income. Any gain allocated to the Partners upon the sale a Sale or other taxable disposition Disposition of any Partnership asset property shall, to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 3 contracts
Samples: Shelbourne Properties I Inc, Shelbourne Properties Iii Inc, Shelbourne Properties Ii Inc
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, Property shall to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit CSection 6.3(b), be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture IncomeIncome (including deductions taken by any Partner with respect to Contributed Property prior to the time such Property was contributed to the Partnership).
Appears in 2 contracts
Samples: Hammons John Q Hotels Inc, Hammons John Q Hotels Inc
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit C, this Section 4.2 be characterized as Recapture Income in the same proportions and to the same extent as such Partners (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 2 contracts
Samples: General Partnership Agreement (DCP Midstream Partners, LP), General Partnership Agreement (DCP Midstream Partners, LP)
Recapture Income. Any gain allocated to the Partners upon the ---------------- sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and --------- to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 2 contracts
Samples: Host Marriott L P, Host Marriott Trust
Recapture Income. Any In accordance with Regulations Sections 1.1245-1(e) and 1.1250-1(f), any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit CC hereto, be characterized as Recapture Income in the same proportions and to the same extent as such Partners (or their predecessors in interest) have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 2 contracts
Samples: CBL & Associates Limited Partnership, CBL & Associates Limited Partnership
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit Cthis Section 6.3, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 2 contracts
Samples: Tarantula Ventures LLC, Dupont Fabros Technology, Inc.
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 2 contracts
Samples: National Health Realty Inc, Burnham Pacific Properties Inc
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.. Exhibit 10.1
Appears in 1 contract
Samples: Agreement (Education Realty Operating Partnership L P)
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible after taking into account other required allocations of gain pursuant to Exhibit CSections 5.1(b) through (d), be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 1 contract
Samples: Four Springs Capital Trust
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit CSection 6.3, shall be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 1 contract
Samples: Irt Property Co
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, shall to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit CSection 6.2, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 1 contract
Samples: Prologis
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, to the extent possible possible, after taking into account other required allocations of gain pursuant to Section 6.1.C. and Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 1 contract
Samples: Cornerstone Properties Inc
Recapture Income. Any taxable gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, shall to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 1 contract
Samples: Highwoods Properties Inc
Recapture Income. Any gain allocated to the Partners upon the sale or other taxable disposition of any Partnership asset shall, shall to the extent possible possible, after taking into account other required allocations of gain pursuant to Exhibit C, be characterized as Recapture Income in the same proportions and to the same extent as such Partners have been allocated any deductions directly or indirectly giving rise to the treatment of such gains as Recapture Income.
Appears in 1 contract
Samples: Carramerica Realty Corp