Protected Units means any of the following:
Protected Units means (1) solely those OP Units or Series A Preferred OP Units issued on the Closing Date and held by a Protected Partner and (2) any OP Units or Series A Preferred OP Units thereafter issued by the Operating Partnership to Protected Partners in exchange for Protected Units held by Protected Partners in a transaction in which the transferee’s adjusted basis in the issued OP Units or Series A Preferred OP Units is determined, in whole or in part, by reference to the transferee’s basis in Protected Units. Notwithstanding the foregoing, a Protected Unit shall cease to constitute a Protected Unit upon (1) the death of the Protected Partner holding such Protected Unit and such death results in a step-up in the tax basis such Protected Unit or (2) the sale, exchange, transfer or other disposition of such Protected Unit (other than any sale or exchange transaction in which the transferee’s basis is determined, in whole or in part, by reference to the adjusted basis of the transferor). In addition, upon the death of any Indirect Owner in a Protected Partner (if such death results in a step-up in the tax basis in such Protected Units), or upon an Indirect Owner’s sale, exchange, transfer or other disposition of some or all of such Indirect Owner’s equity interest in a Protected Partner (other than any sale or exchange transaction in which the transferee’s basis is determined, in whole or in part, by reference to the adjusted basis of the transferor Indirect Owner), the Protected Units treated as held by such Protected Partner shall be reduced such that the Protected Units held by such Protected Partner shall equal the Protected Units that would have been held by the Indirect Owners in the aggregate, following such event, had the Indirect Owners directly received Protected Units in the Formation Transactions and the Indirect Owner had either directly transferred a portion of such Protected Units or died holding such Protected Units (if such death results in a step-up in the tax basis such Protected Units and taking into account all prior transactions involving the death of an Indirect Owner in such Protected Partner or the sale, exchange, transfer or other disposition of an Indirect Owner’s equity interest in such Protected Partner (other than a sale or exchange transaction in which the transferee’s basis is determined in whole or in part by reference to the adjusted basis of the transferor Indirect Owner)).
Examples of Protected Units in a sentence
Each Protected Partner hereby covenants and agrees to provide, on its own behalf or through its legal representatives, the Partnership with written notice of any change in the direct or indirect ownership of Protected Units (including, but not limited to, the death of such Protected Partner or any Indirect Owner thereof) promptly after any such change in ownership.
This Agreement may not be amended, directly or indirectly (including by reason of a merger between Vornado OP and another entity) except by a written instrument signed by Vornado, as general partner of Vornado OP, and approved by (i) the SCR Partners holding seventy-six percent (76%) of the then outstanding Protected Units and (ii) if any of Robert H.
Each Protected Partner and Obligated Partner, hereby covenants and agrees to provide, on its own behalf or through its legal representatives, GGP Partnership with prompt written notice of any transfer of Protected Units or the death of such Protected Partner or Obligated Partner.
All occupants of Protected Units (as defined in California Government Code Section 66300(d)(2)(F)(vi)) being displaced by the Project have the right to remain in their units until six (6) months before the start of construction activities with proper notice subject to Chapter 16 (Relocation Assistance) of Division 7, Title I of the California Government Code (“Chapter 16”).
In addition, in the case of a breach of Section 2, in no event shall the gain taken into account for purposes of computing the damages payable under this Section 4(a) exceed the amount of gain that would have been recognized by the SRW Partner with respect to the Protected Units if the Trust had sold the Protected Property in a fully taxable transaction on the day following the closing of the SRW Merger for a purchase price equal to the 704(c) Value of such Protected Property.
More Definitions of Protected Units
Protected Units. Means only those PREIT OP Units issued to Crown Partnership in the Merger Transactions, or any PREIT OP Units thereafter issued by PREIT Partnership to the Crown Partnership or any other Contributors in exchange for such Protected Units or solely with respect to such Protected Units or pursuant to the exercise of an option pursuant to which PREIT Partnership acquires limited partnership interests in CFLP and WCALP from Crown Partnership as set forth in the Crown Contribution Agreement. The term Protected Units shall not include any other PREIT OP Units hereafter acquired by a Contributor, whether from PREIT Partnership or otherwise.
Protected Units means, with respect to a Company, Class B Units of the Company issued in the Formation Transactions and any interests in the Company thereafter issued by any Company in exchange for or solely with respect to Protected Units.
Protected Units. Means those Vornado OP Units issued to the SCR Unitholders in connection with the Merger, or any partnership interests in Vornado OP (or any other entity that is treated as a partnership for federal income tax purposes) thereafter issued by Vornado OP to the SCR Unitholders in exchange for such Protected Units or with respect to such Protected Units. The term Protected Units shall not include any other Vornado OP Units hereafter acquired by an SCR Unitholder, whether from Vornado OP (except as described in the immediately preceding sentence) or otherwise.
Protected Units means (1) solely those Series T Preferred Units issued on the date of the execution of this Amendment and held by a Protected Partner and (2) any Partnership Units thereafter issued by the Partnership to Protected Partners in exchange for Protected Units held by Protected Partners in a transaction in which the transferee’s adjusted basis in the issued Partnership Units is determined, in whole or in part, by reference to the transferee’s basis in Protected Units. Notwithstanding the foregoing, a Protected Unit shall cease to constitute a Protected Unit upon (1) the death of the Protected Partner holding such Protected Unit and such death results in a step-up in the tax basis such Protected Unit or (2) the sale, exchange, transfer or other disposition of such Protected Unit (other than any sale or exchange transaction in which the transferee’s basis is determined, in whole or in part, by reference to the adjusted basis of the transferor). In addition, upon the death of any Indirect Owner in a Protected Partner (if such death results in a step-up in the tax basis in such Protected Units), or upon an Indirect Owner’s sale, exchange, transfer or other disposition of some or all of such Indirect Owner’s equity interest in a Protected Partner (other than any sale or exchange transaction in which the transferee’s basis is determined, in whole or in part, by reference to the adjusted basis of the transferor Indirect Owner), the Protected Units treated as held by such Protected Partner shall be reduced such that the Protected Units held by such Protected Partner shall equal the Protected Units that would have been held by the Indirect Owners in the aggregate, following such event, had the Indirect Owners directly received Protected Units in the Contribution and the Indirect Owner had either directly transferred a portion of such Protected Units or died holding such Protected Units (if such death results in a step-up in the tax basis such Protected Units and taking into account all prior transactions involving the death of an Indirect Owner in such Protected Partner or the sale, exchange, transfer or other disposition of an Indirect Owner’s equity interest in such Protected Partner (other than a sale or exchange transaction in which the transferee’s basis is determined in whole or in part by reference to the adjusted basis of the transferor Indirect Owner)).
Protected Units. Means only those Partnership Units issued to the Sale Restriction Partners in the Xxxxxxx Merger, or any Partnership Units thereafter issued by the Partnership to the Sale Restriction Partners in exchange for such Protected Units or solely with respect to such Protected Units. The term Protected Units shall not include any other Units hereafter acquired by a Sale Restriction Partner, whether from the Partnership or otherwise.
Protected Units means (1) solely those OP Units issued in the Contribution and acquired by a Protected Partner either at original issuance or from a Protected Partner in a transaction in which the transferee’s adjusted basis, as determined for federal income tax purposes, is determined, in whole or in part, by reference to the adjusted basis of the transferor Protected Partner in such Protected Units, (2) any OP Units thereafter issued by the OP to a Protected Partner in exchange for Protected Units held by such Protected Partner in a transaction in which the Protected Partner’s adjusted basis, as determined for federal income tax purposes, in the newly issued OP Units is determined, in whole or in part, by reference to such Protected Partner’s adjusted basis, as determined for federal income tax purposes, in the Protected Units exchanged, and (3) OP Units received by an Indirect Owner of a Protected Partner in a distribution to such Indirect Owner in a transaction in which all or any portion of the gain or loss is not recognized by the Protected Partner. Notwithstanding the foregoing, a Protected Unit shall cease to constitute a Protected Unit upon (X) the death of the Protected Partner holding such Protected Unit if, as a result of the death of the Protected Partner, the transferee of such unit receives an adjusted basis in such unit for federal income tax purposes that is equal to the fair market value of such unit on the date of the Protected Partner’s death or (Y) any sale, exchange, transfer or other disposition of such Protected Unit (except as provided in clauses (2) and (3) above and other than any sale or exchange transaction in which the transferee’s adjusted basis, as determined for federal income tax purposes, is determined, in whole or in part, by reference to the adjusted basis, as determined for federal income tax purposes, of the transferor). In addition, upon the death of any Indirect Owner in a Protected Partner (not including an Indirect Owner that holds its indirect interest through an S corporation and only if, as a result of the death of the Indirect Owner, the transferee of the Indirect Owner’s direct or indirect equity interest in the Protected Partner receives an adjusted basis in such equity interest for federal income tax purposes that is equal to the fair market value of such equity interest on the date of the Indirect Owner’s death), or upon the sale, exchange, transfer or other disposition by an Indirect Owner (not including an Indirect Owne...
Protected Units means solely those TMP Partnership Units issued in the Transaction and held by Protected Partners and any TMP Partnership Units thereafter issued by TMP in exchange for Protected Units in a transaction in which the transferee's adjusted basis, as determined for federal income tax purposes, in the issued Protected Units is determined, in whole part, by reference, to the transferee's adjusted basis, as determined for federal income tax purposes, the Protected Units. For the avoidance of doubt, Protected Units shall not include LTIP Units or Class C Units.