Common use of Revaluations Clause in Contracts

Revaluations. Notwithstanding Section 6.4(A), Tax Items with respect to Partnership property that is contributed to the Partnership by a Partner shall be shared among the Partners for income tax purposes pursuant to Regulations promulgated under Section 704(c) of the Code, so as to take into account the variation, if any, between the basis of the property to the Partnership and its initial Gross Asset Value. With respect to Partnership property that is initially contributed to the Partnership upon its formation, such variation between basis and initial Gross Asset Value shall be taken into account under the "traditional method" as described in Proposed Treasury Regulation Section 1.704-3(b) and Treasury Regulation Section 1.704-1(c)(2). With respect to properties subsequently contributed to the Partnership the Partnership shall account for such variation under any method approved under Section 704(c) of the Code and the applicable regulations as chosen by the General Partner. In the event the Gross Asset Value of any Partnership asset is adjusted pursuant to subparagraph (b) of the definition of Gross Asset Value (provided in Article 1 of this Agreement), subsequent allocations of Tax Items with respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Section 704(c) of the Code and the applicable regulations.

Revaluations. Notwithstanding Section 6.4(A)6.04(a) hereof, Tax Items with respect to Partnership property Property that is contributed to the Partnership by with a Gross Asset Value that varies from its basis in the hands of the contributing Partner immediately preceding the date of contribution shall be shared allocated among the Partners Holders of Partnership Units for income tax purposes pursuant to Regulations promulgated under Code Section 704(c) of the Code, so as to take into account the such variation, if any, between the basis of the property to the Partnership and its initial Gross Asset Value. With respect to Partnership property that is initially contributed to the Partnership upon its formation, such variation between basis and initial Gross Asset Value shall be taken into account under the "traditional method" as described in Proposed Treasury Regulation Section 1.704-3(b) and Treasury Regulation Section 1.704-1(c)(2). With respect to properties subsequently contributed to the Partnership the The Partnership shall account for such variation under any method approved under Code Section 704(c) of the Code and the applicable regulations Regulations as chosen by the General Partner, including, without limitation, the “remedial allocation method” as described in Regulations Section 1.704-3(d); provided, however, that the “traditional method” shall be used for any assets acquired by the Partnership pursuant to merger and other contracts and agreements entered into by the Partnership or the General Partner in connection with the IPO. In the event that the Gross Asset Value of any Partnership partnership asset is adjusted pursuant to subparagraph subsection (b) of the definition of “Gross Asset Value Value” (provided in Article 1 of this AgreementI hereof), subsequent allocations of Tax Items with respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Code Section 704(c) of the Code and the applicable regulationsRegulations or under any method approved under Code Section 7.04(c) and the applicable Regulations as chosen by the General Partner.

Revaluations. Notwithstanding Section 6.4(A), Tax Items with respect to Partnership property that is contributed to the Partnership by a Partner shall be shared among the Partners for income tax purposes pursuant to Regulations promulgated under Section 704(c) of the Code, so as to take into account the variation, if any, between the basis of the property to the Partnership and its initial Gross Asset Value. With respect to Partnership property that is initially contributed to the Partnership upon its formation, such variation between basis and initial Gross Asset Value shall be taken into account under the "traditional method" as described in Proposed Treasury Regulation Section ss. 1.704-3(b) and Treasury Regulation Section ss. 1.704-1(c)(2). With respect to properties subsequently contributed to the Partnership Partnership, the Partnership shall account for such variation under any method approved under Section 704(c) of the Code and the applicable regulations as chosen by the General Partner. In the event the Gross Asset Value of any Partnership asset is adjusted pursuant to subparagraph (b) of the definition of Gross Asset Value (provided in Article 1 of this the Agreement), subsequent allocations of Tax Items with respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Section 704(c) of the Code and the applicable regulations.

Revaluations. Notwithstanding Section 6.4(A)6.4.A, Tax Items with respect to Partnership property that is contributed to the Partnership by a Partner shall be shared among the Partners for income tax purposes pursuant to Regulations promulgated under Section 704(c) of the Code, so as to take into account the variation, if any, between the basis of the property to the Partnership and its initial Gross Asset Value. With respect to Partnership property that is initially properties contributed to the Partnership upon its formationPartnership, such variation between basis and initial Gross Asset Value shall be taken into account under the "traditional method" as described in Proposed Treasury Regulation Section 1.704-3(b) and Treasury Regulation Section 1.704-1(c)(2). With respect to properties subsequently contributed to the Partnership the Partnership shall account for such variation under any method approved under Section 704(c704 (c) of the Code and the applicable regulations as chosen by the General Partner. In the event the Gross Asset Value of any Partnership asset is adjusted pursuant to subparagraph (b) of the definition of Gross Asset Value (provided in Article 1 of this Agreement), subsequent allocations of Tax Items with respect to such asset (including but not limited to the Property) shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Section 704(c704 (c) of the Code and the applicable regulations.regulations consistent with the requirements of Regulations Section 1.704-1(b)(2)(iv)(g) using the "traditional method" (with the "ceiling rule") as described in Regulations Section 1.704-3(b)(1)