SECTION 704(C) METHOD AND ALLOCATIONS. Notwithstanding any provision of the Partnership Agreement, the Partnership shall use the “traditional method” under Regulations § 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code (with no “curative allocations” to offset the effects of the “ceiling rule,” including upon any sale of a Protected Property).
Appears in 4 contracts
Samples: Tax Protection Agreement (Gc Net Lease Reit, Inc.), Tax Protection Agreement (Gc Net Lease Reit, Inc.), Tax Protection Agreement (Gc Net Lease Reit, Inc.)
SECTION 704(C) METHOD AND ALLOCATIONS. Notwithstanding any provision of the Partnership Agreement, the Partnership shall use the “traditional method” under Treasury Regulations § Section 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code (with no “curative allocations” respect to offset the effects of the “ceiling rule,” including upon any sale of a Protected Contributed Property).
Appears in 4 contracts
Samples: Tax Protection Agreement (Bluerock Residential Growth REIT, Inc.), Contribution Agreement (Bluerock Residential Growth REIT, Inc.), Protection Agreement (Bluerock Residential Growth REIT, Inc.)
SECTION 704(C) METHOD AND ALLOCATIONS. Notwithstanding any provision of the Partnership Agreement, the Partnership shall use the “traditional method” under Treasury Regulations § Section 1.704-3(b) for purposes of making all allocations under Section 704(c) of the Code (with no “curative allocations” respect to offset the effects of the “ceiling rule,” including upon any sale of a Protected Gain Limitation Property).
Appears in 1 contract
Samples: Tax Protection Agreement (Wheeler Real Estate Investment Trust, Inc.)
