Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes, (a) the StadCo Contribution Amount, and any amounts expended by StadCo pursuant to Article 7 (
Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes, (a) the StadCo Contribution Amount shall be treated as prepaid rent paid by StadCo to the Authority and (b) the aggregate amount of that prepaid rent shall be allocated for purposes of Treasury Regulations Section 1.467-1(c)(2)(ii) in equal annual installments (prorated for partial calendar years) to each year during the term of this Agreement (determined by assuming that the Agreement does not terminate early in accordance with clause (ii) of the definition of Term Expiration Date). For each year during the foregoing term, solely for federal and applicable state and local income tax purposes, StadCo shall accrue interest income and the Authority shall accrue corresponding interest expense on the resulting “section 467 loan” in accordance with the principles of Treasury Regulations Section 1.467-4. Any such interest shall be taken into account in determining the balance of such a “section 467 loan”, but in no event shall any principal or interest on such a “section 467 loan” be separately payable (including upon any termination of this Agreement).
Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes and without implication for any other provision of this Agreement, (a) to the extent the Stadium or any other Improvements are funded by StadCo as Project Improvements Work or pursuant to Article 7 (
Treatment of StadCo Contribution Amount. The Parties agree and acknowledge that, for all federal and applicable state and local income tax purposes, but only for those purposes, (a) the StadCo Contribution Amount, and any amounts expended by StadCo pursuant to Article 7 or 8 of this Lease shall be treated as prepaid rent paid by StadCo to the Authority and (b) the aggregate amount of that prepaid rent shall be allocated for purposes of Treasury Regulations Section 1.467-1(c)(2)(ii) in equal annual installments (prorated for partial calendar years) to each year during the term of this Agreement (determined by assuming that the Agreement does not terminate early in accordance with clause (ii) of the definition of Term Expiration Date). For each year during the foregoing term, solely for federal and applicable state and local income tax purposes, StadCo shall accrue interest income and the Authority shall accrue corresponding interest expense on the resulting “section 467 loan” in accordance with the principles of Treasury Regulations Section 1.467-4. Any such interest shall be taken into account in determining the balance of such a “section 467 loan”, but in no event shall any principal or interest on such a “section 467 loan” be separately payable (including upon any termination of this Agreement).1
