In General. Except as otherwise provided in this Section 6.4, for income tax purposes each item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 35 contracts
Samples: Agreement and Plan of Merger (Dupont Fabros Technology, Inc.), Digital Realty Trust, L.P., Digital Realty Trust, L.P.
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.3 hereof.
Appears in 30 contracts
Samples: Agreement (Rexford Industrial Realty, Inc.), Agreement (Indus Realty Trust, Inc.), Orion Office REIT Inc.
In General. Except as otherwise provided in this Section 6.4, for income tax purposes each item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 23 contracts
Samples: Carey Watermark Investors 2 Inc, Assignment and Assumption Agreement (Amb Property Lp), Liability Agreement (Arden Realty Inc)
In General. Except as otherwise provided in this Section 6.4, for income tax purposes each item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 19 contracts
Samples: Constructive Ownership Definition (Amb Property Corp), Constructive Ownership Definition (Amb Property Corp), Amb Property Lp
In General. Except as otherwise provided in this Section 6.4, for income tax purposes each item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 17 contracts
Samples: Form of Agreement (Corporate Property Associates 18 Global Inc), Corporate Property Associates 17 - Global INC, Corporate Property Associates 18 Global Inc
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations, each Company item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.3 hereof.
Appears in 12 contracts
Samples: Limited Liability Company Agreement (Mobile Infrastructure Corp), Limited Liability Company Agreement (Mobile Infrastructure Corp), Limited Liability Company Agreement (BrightSpire Capital, Inc.)
In General. Except as otherwise provided in this Section 6.4, for income tax purposes each item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections Section 6.2 and 6.3.
Appears in 7 contracts
Samples: Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/), Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/), Limited Partnership Agreement (Tanger Properties LTD Partnership /Nc/)
In General. Except as otherwise provided in this Section 6.46.3, for income tax purposes each item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3Section 6.1.
Appears in 6 contracts
Samples: Agreement (Aviv Reit, Inc.), Hot Springs Cottages Owner, LLC, Omega Healthcare Investors Inc
In General. Except as otherwise provided in this Section 6.45.4, for income tax purposes under the Code and the Regulations each Company item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 5.2 and 6.35.3.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Wayne Farms, Inc.), Limited Liability Company Agreement (Wayne Farms, Inc.), Limited Liability Company Operating Agreement (Genesis Healthcare, Inc.)
In General. Except as otherwise provided in this Section 6.46.3, for income tax purposes under the Code and the Regulations each Company item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 6.1 and 6.3Section 6.2.
Appears in 4 contracts
Samples: Operating Agreement (Biote Corp.), Letter Agreement (FTAC Athena Acquisition Corp.), Limited Liability Company Agreement (OppFi Inc.)
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations, each Company item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.3 hereof.
Appears in 4 contracts
Samples: Operating Agreement (Healthpeak Properties, Inc.), Limited Liability Company Agreement (Kimco Realty OP, LLC), Limited Liability Company Agreement (Kimco Realty Corp)
In General. Except as otherwise provided in this Section 6.45.4, for income tax purposes under the Code and the Regulations each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 5.2 and 6.35.3.
Appears in 4 contracts
Samples: Moelis & Co, Moelis & Co, Moelis & Co
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations, each Company item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.3 hereof.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Bre Properties Inc /Md/), Limited Liability Company Agreement (Bre Properties Inc /Md/), Limited Liability Company Agreement (Inland Real Estate Corp)
In General. Except as otherwise provided in this Section 6.45.4, for income tax purposes under the Code and the Regulations each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 Section 5.2 and 6.3Section 5.3.
Appears in 3 contracts
Samples: Agreement (Perella Weinberg Partners), Business Combination Agreement (FinTech Acquisition Corp. IV), Perella Weinberg Partners
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations each Partnership item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.3 hereof.
Appears in 3 contracts
Samples: Hartman Short Term Income Properties XX, Inc., Douglas Emmett Inc, Global Signal Inc
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations each Partnership item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders in the same manner as its correlative item of “book” "Book" income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.3 hereof.
Appears in 2 contracts
Samples: Agreement (Cornerstone Realty Income Trust Inc), Cornerstone Realty Income Trust Inc
In General. Except as otherwise provided in this Section 6.44.3, for income tax purposes each item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3Section 4.2.
Appears in 2 contracts
Samples: Contribution Agreement (Thomas Properties Group Inc), Contribution Agreement (Thomas Properties Group Inc)
In General. Except as otherwise provided in this Section 6.45.3, for income tax purposes under the Code and the Regulations each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 5.1 and 6.3Section 5.2.
Appears in 2 contracts
Samples: Business Combination Agreement (dMY Technology Group, Inc.), Rush Street Interactive, Inc.
In General. Except as otherwise provided in this Section 6.4, for federal income tax purposes purposes, each item of Partnership income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders Unitholders in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 2 contracts
In General. Except as otherwise provided in this Section 6.4, for federal income tax purposes each item of income, gain, loss loss, and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss loss, or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 2 contracts
Samples: Tarantula Ventures LLC, Dupont Fabros Technology, Inc.
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations, each Company item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 1 contract
In General. Except as otherwise provided in this Section 6.45.3, for income tax purposes under the Code and the Regulations each Partnership item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 5.1 and 6.30.
Appears in 1 contract
Samples: Business Combination Agreement (dMY Technology Group, Inc.)
In General. Except as otherwise provided in this Section 6.4, ---------- for income tax purposes each item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections Section 6.2 and 6.3.
Appears in 1 contract
Samples: Center Trust Inc
In General. Except as otherwise provided in this Section 6.4, ---------- for income tax purposes each item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3.
Appears in 1 contract
Samples: Kilroy Realty Corp
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes each item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 6.2, 6.3 and 6.36.4.
Appears in 1 contract
Samples: Merger Agreement (Bellingham II Associates, L.L.C.)
In General. Except as otherwise provided in this Section 6.46.7, for income tax purposes each item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.6 hereof.
Appears in 1 contract
Samples: Prime Group Realty Trust
In General. Except as otherwise provided in this Section 6.4, for income tax purposes each item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections Section 6.2 and 6.3.
Appears in 1 contract
Samples: Tanger Factory Outlet Centers Inc
In General. Except as otherwise provided in this Section 6.46.7, for income tax purposes each item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders Partners in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.36.6 hereof.
Appears in 1 contract
Samples: Prime Group Realty Trust
In General. Except as otherwise provided in this Section 6.4, 6.6 for income tax purposes each item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 6.4 and 6.36.5.
Appears in 1 contract
Samples: Limited Partnership Agreement (Equity Residential Properties Trust)
