Section 704(c) Method. The Partnership shall report allocations of income, gain, loss and deduction (as computed for tax purposes) with respect to the Contribution so as to take account of the Section 704(c) built-in gain of such properties under Code Section 704(c) or the principles set forth in Treasury Regulations section 1.704-3(a), as the case may be, using the traditional method (as specifically provided in Treasury Regulations section 1.704-3(b)).
Appears in 12 contracts
Samples: Interest Contribution Agreement (Landmark Apartment Trust of America, Inc.), Interest Contribution Agreement (Landmark Apartment Trust of America, Inc.), Interest Contribution Agreement (Landmark Apartment Trust of America, Inc.)
Section 704(c) Method. The Operating Partnership shall report allocations of income, gain, loss and deduction (as computed for tax purposes) with respect to the Contribution Properties so as to take account of the Section 704(c) built-built in gain of such properties under Code Section 704(c) or the principles set forth in Treasury Regulations section 1.704-3(a), as the case may be, using the traditional method (as specifically provided in Treasury Regulations section 1.704-3(b)).
Appears in 2 contracts
Samples: Tax Protection Agreement (NETSTREIT Corp.), Tax Protection Agreement (NETSTREIT Corp.)
Section 704(c) Method. The Partnership shall report allocations of income, gain, loss and deduction (as computed for tax purposes) with respect to the each Contribution so as to take account of the Section 704(c) built-in gain of such properties under Code Section 704(c) or the principles set forth in Treasury Regulations section 1.704-3(a), as the case may be, using the traditional method (as specifically provided in Treasury Regulations section 1.704-3(b)).
Appears in 1 contract
Samples: Tax Protection Agreement (Landmark Apartment Trust, Inc.)
