Common use of U.S. Tax Treatment of Notes and the Issuer Clause in Contracts

U.S. Tax Treatment of Notes and the Issuer. (a) Each of the Issuer and the Co-Issuer intends that, for U.S. federal income tax purposes, the Notes be treated as debt and that the Issuer be treated as a "qualified REIT subsidiary" (within the meaning of Section 856(i) of the Code). Each prospective purchaser and any subsequent transferee of a Note or any interest therein shall, by virtue of its purchase or other acquisition of such Note or interest therein, be deemed to have agreed to treat such Note in a manner consistent with the preceding sentence for U.S. federal income tax purposes.

U.S. Tax Treatment of Notes and the Issuer. (a) Each of the Issuer and the The Co-Issuer intends Issuers intend that, for U.S. federal federal, state or local income tax, franchise tax and any other income tax purposes, the Notes be treated as debt and that the Issuer be treated as a "qualified Qualified REIT subsidiary" (within the meaning of Section 856(i) of the Code)Subsidiary. Each prospective purchaser and any subsequent transferee of a Note or any interest therein shall, by virtue of its purchase or other acquisition of such Note or interest therein, be deemed to have agreed to treat such Note in a manner consistent with the preceding sentence for U.S. federal income tax purposes.

U.S. Tax Treatment of Notes and the Issuer. (a) Each of the Issuer and the Co-The Issuer intends that, for U.S. federal income tax purposes, the Notes be treated as debt and that the Issuer be treated as an entity disregarded with respect to its sole beneficial owner or as a "qualified REIT subsidiary" (within the meaning of Section 856(i) of the Code)partnership if held for U.S. federal income tax purposes by more than one Holder. Each prospective purchaser and any subsequent transferee of a Note or any interest therein shall, by virtue of its purchase or other acquisition of such Note or interest therein, be deemed to have agreed to treat such Note in a manner consistent with the preceding sentence for U.S. federal income tax purposes.

U.S. Tax Treatment of Notes and the Issuer. (a) Each of the Issuer and the Co-Issuer intends that, for U.S. federal income tax purposes, the Notes be treated as debt and that the Issuer be treated as a "qualified Qualified REIT subsidiary" (within the meaning of Section 856(i) of the Code)Subsidiary. Each prospective purchaser and any subsequent transferee of a Note or any interest therein shall, by virtue of its purchase or other acquisition of such Note or interest therein, be deemed to have agreed to treat such Note in a manner consistent with the preceding sentence for U.S. federal income tax purposes.