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.
Appears in 2 contracts
Samples: Contribution Agreement (STAG Industrial, Inc.), Contribution Agreement (STAG Industrial, Inc.)
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.
Appears in 2 contracts
Samples: Contribution Agreement (STAG Industrial, Inc.), Contribution Agreement (STAG Industrial, Inc.)