REIT Termination Event. REIT Termination Event shall mean the earliest to occur of (1) the determination by the Manager that the Company shall cease to qualify as a REIT; (2) the determination by the Manager, based upon the advice of counsel, that the Company has ceased to qualify as a REIT; (3) the “determination”, as defined by IRC 1313(a), that the Trust has ceased to qualify as a REIT; (4) the filing of a federal tax Return, with the consent of the Manager, for any taxable year, in which the Company does not elect to be taxed as REIT.
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)
