TREATMENT AS CONTRIBUTION. The transfer, assignment and exchange of interests effectuated with respect to the Operating Partnership, pursuant to this Contribution Agreement, shall constitute a "Capital Contribution" pursuant to Article IV of the OP Agreement and is intended to be governed by Section 721(a) of the Internal Revenue Code of 1986, as amended (the "Code").
Appears in 9 contracts
Samples: Contribution Agreement (Tower Realty Trust Inc), Contribution Agreement (Tower Realty Trust Inc), Contribution Agreement (Tower Realty Trust Inc)
TREATMENT AS CONTRIBUTION. The transfer, assignment and exchange of interests effectuated with respect to the Operating Partnership, Partnership pursuant to this Contribution Agreement, Agreement shall constitute a "Capital Contribution" pursuant to Article IV of the OP Agreement and is intended to be governed by Section 721(a) of the Internal Revenue Code of 1986, as amended (the "Code").
Appears in 6 contracts
Samples: Contribution Agreement (Equity Office Properties Trust), Contribution Agreement (Equity Office Properties Trust), Contribution Agreement (Equity Office Properties Trust)
TREATMENT AS CONTRIBUTION. The transfer, assignment and exchange of interests effectuated with respect to the Operating Partnership, pursuant to this Contribution AgreementAgreement shall constitute, shall constitute a "Capital Contribution" pursuant to Article IV 4 of the OP Agreement and is intended to be governed by Section 721(a) of the Internal Revenue Code of 1986, as amended (the "CodeCODE").
Appears in 4 contracts
Samples: Contribution Agreement (Arden Realty Group Inc), Contribution Agreement (Arden Realty Group Inc), Contribution Agreement (Arden Realty Group Inc)
TREATMENT AS CONTRIBUTION. The transfer, assignment and exchange of interests effectuated with respect to the Operating Partnership, pursuant to this Contribution Agreement, shall constitute a "Capital Contribution" pursuant to Article IV 4 of the OP Agreement and is intended to be governed by Section 721(a) of the Internal Revenue Code of 1986, as amended (the "CodeCODE").
Appears in 2 contracts
Samples: Contribution Agreement (Tower Realty Trust Inc), Contribution Agreement (Tower Realty Trust Inc)
TREATMENT AS CONTRIBUTION. The transfer, assignment and exchange of interests effectuated with respect to the Operating Partnership, pursuant to this Contribution Agreement, shall constitute a "Capital ContributionCAPITAL CONTRIBUTION" pursuant to Article IV 4 of the OP Agreement and is intended to be governed by Section 721(a) of the Internal Revenue Code of 1986, as amended (the "CodeCODE"). The transfer, assignment and exchange of interests effectuated with respect to the Company pursuant to this Agreement is intended to be governed by Section 351 of the Internal Revenue Code of 1986, as amended (the "CODE").
Appears in 2 contracts
Samples: Contribution Agreement (Tower Realty Trust Inc), Contribution Agreement (Tower Realty Trust Inc)
TREATMENT AS CONTRIBUTION. The transfer, assignment and exchange of interests effectuated with respect to the Operating Partnership, pursuant to this Contribution Agreement, shall constitute a "Capital Contribution" pursuant to Article IV of the OP Agreement and is intended to be governed by Section ARTICLE 721(a) of the Internal Revenue Code of 1986, as amended (the "Code").
Appears in 1 contract
TREATMENT AS CONTRIBUTION. The transfer, assignment and exchange of interests effectuated with respect to the Operating Partnership, pursuant to this Contribution AgreementAgreement shall constitute, shall constitute a "Capital Contribution" pursuant to Article IV 4 of the OP Agreement and is intended to be governed by Section 721(a) of the United States Internal Revenue Code of 1986, as amended (the "CodeCODE").
Appears in 1 contract
