Common use of Tax Consequences to Contributor Clause in Contracts

Tax Consequences to Contributor. Notwithstanding anything to the contrary contained in this Agreement, including without limitation the use of words and phrases such as “sell,” “sale,” “purchase” and “pay,” the parties hereto acknowledge and agree that with respect to any portion of the Consideration that is payable in OP Units, that it is their intent that the contribution of the Contributed Interests to the Operating Partnership shall be governed by Section 721 of the Internal Revenue Code of 1986, as amended (the “Code”), unless and to the extent otherwise required by applicable law.