Tax Treatment of Contribution. The parties hereto intend and agree that, for federal income tax purposes, the contributions, transfers, conveyances and assignments of a Seller’s interest in the Property for OP Units shall be treated as contributions of interests in the Property by Seller to Purchaser in accordance with Section 721 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 3 contracts
Samples: Purchase and Sale Agreement (Condor Hospitality Trust, Inc.), Purchase and Sale Agreement (Condor Hospitality Trust, Inc.), Purchase and Sale Agreement (Condor Hospitality Trust, Inc.)
Tax Treatment of Contribution. The parties hereto intend and agree that, for federal income tax purposes, the contributions, transfers, conveyances and assignments of a Seller’s 's interest in the Property for OP Units shall be treated as contributions of interests in the Property by Seller to Purchaser in accordance with Section 721 of the Internal Revenue Code of 1986, as amended (the “"Code”").
Appears in 2 contracts
Samples: Purchase and Sale Agreement, Purchase and Sale Agreement (Condor Hospitality Trust, Inc.)
Tax Treatment of Contribution. The parties hereto intend and agree that, for federal income tax purposes, the contributions, transfers, conveyances and assignments of a SellerContributor’s respective interest in the Property for OP Units Units, to the extent such consideration is so elected in accordance with Section 1.2(e), shall be treated as contributions of interests in the Property by Seller such applicable Contributor to Purchaser the Operating Partnership in accordance with Section 721 of the Internal Revenue Code of 1986, as amended (the “Code”).
Appears in 1 contract
Samples: Contribution Agreement (Independence Realty Trust, Inc)
