Subsidiary Partnership Tax Classification. Each of the Operating Partnership and each Subsidiary that is a partnership or a limited liability company under state law has been at all relevant times properly classified as a partnership or a disregarded entity, and not as a corporation or an association taxable as a corporation, for federal income tax purposes.
Appears in 15 contracts
Sources: At Market Issuance Sales Agreement (Strawberry Fields REIT, Inc.), At Market Issuance Sales Agreement (Bluerock Residential Growth REIT, Inc.), Underwriting Agreement (Bluerock Residential Growth REIT, Inc.)
Subsidiary Partnership Tax Classification. Each of the Operating Partnership and each Subsidiary that is a partnership or a limited liability company under state law has been at all relevant times properly classified as a partnership or a disregarded entity, and not as a corporation or an association taxable as a corporation, for federal income tax purposes, except for ▇▇▇▇▇▇▇ Development, LLC, ▇▇▇▇▇▇▇ Interests, LLC, ▇▇▇▇▇▇▇ Real Estate, LLC and ▇▇▇▇▇▇▇ Management LLC, which have elected to be treated as taxable REIT subsidiaries pursuant to Code Section 856(l)1).
Appears in 2 contracts
Sources: Underwriting Agreement (Wheeler Real Estate Investment Trust, Inc.), Underwriting Agreement (Wheeler Real Estate Investment Trust, Inc.)
Subsidiary Partnership Tax Classification. Each of the Operating Partnership and each Subsidiary that is a partnership or a limited liability company under state law has been at all relevant times properly classified as a partnership or a disregarded entity, and not as a corporation or an association taxable as a corporation, for federal income tax purposes, except for ▇▇▇▇▇▇▇ Development, LLC, ▇▇▇▇▇▇▇ Interests, LLC, ▇▇▇▇▇▇▇ Real Estate, LLC and ▇▇▇▇▇▇▇ Management LLC, which have elected to be treated as taxable REIT subsidiaries pursuant to Code Section 856(l)(1).
Appears in 1 contract
Sources: Underwriting Agreement (Wheeler Real Estate Investment Trust, Inc.)