Common use of Tax Treatment of Contribution Clause in Contracts

Tax Treatment of Contribution. The contribution, transfer, conveyance and assignment of the SCP Interests to the Operating Partnership from the Contributors is intended to be treated as a transaction in “assets-over” form pursuant to Treas. Reg. 1.708-1(c)(3) qualifying under Section 721(a) of the Code.

Tax Treatment of Contribution. The contribution, transfer, conveyance and assignment of the SCP III Interests to the Operating Partnership from the Contributors is intended to be treated as a transaction in “assets-over” form pursuant to Treas. Reg. 1.708-1(c)(3) qualifying under Section 721(a) of the Code.