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 of Partnership Common Units 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 hereof.
Appears in 18 contracts
Samples: Agreement (Aimco OP L.P.), Aimco OP L.P., Aimco Properties L.P.
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof.
Appears in 18 contracts
Samples: Agreement (Parking REIT, Inc.), Support Agreement (Mobile Infrastructure Corp), Agreement (Mobile Infrastructure Corp)
In General. Except as otherwise provided in this Section 6.46.04, 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 of Partnership Common Units in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 6.02 and 6.3 6.03 hereof.
Appears in 16 contracts
Samples: Agreement (Hannon Armstrong Sustainable Infrastructure Capital, Inc.), Merger Agreement (Ready Capital Corp), Merger Agreement (ZAIS Financial Corp.)
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 of Partnership Common Units 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 hereof.
Appears in 14 contracts
Samples: Aspen REIT, Inc., Safety, Income & Growth, Inc., Safety, Income & Growth, 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 of Partnership Common Units 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 hereof.
Appears in 10 contracts
Samples: CyrusOne Inc., Contribution Agreement (Welsh Property Trust, Inc.), Contribution Agreement (Welsh Property Trust, 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 of Partnership Common Units 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 hereof.
Appears in 10 contracts
Samples: Arbor Realty Trust Inc, Northstar Realty, Northstar Realty
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof.. 37
Appears in 7 contracts
Samples: Agreement and Plan of Merger (American Assets Trust, Inc.), Op Sub Contribution Agreement (American Assets Trust, Inc.), Agreement and Plan of Merger (American Assets Trust, 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 of Partnership Common Units 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 hereof.
Appears in 6 contracts
Samples: Agreement (Arizona Land Income Corp), Agreement (Pacific Office Properties Trust, Inc.), Agreement (Pacific Office Properties Trust, Inc.)
In General. Except as otherwise provided in this Section 6.46.04, 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 of Partnership Common Units in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 6.02 and 6.3 6.03 hereof.
Appears in 5 contracts
Samples: Preston Hollow Community Capital, Inc., Joinder Agreement (Etre Reit, LLC), Ready Capital Corp
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units in the same manner as its correlative item of “book” income, gain, loss or deduction expense is allocated pursuant to Sections 6.2 and 6.3 hereof.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Guide Holdings Inc), Limited Partnership Agreement (Silver Bay Realty Trust Corp.), Limited Partnership Agreement (Silver Bay Realty Trust Corp.)
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 of Partnership Common Units in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 Section 5.1 and 6.3 hereofSection 5.2.
Appears in 4 contracts
Samples: Blue Owl Capital Inc., Blue Owl Capital Inc., Blue Owl Capital Inc.
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 6.3 6.4 hereof.
Appears in 4 contracts
Samples: Agreement (Spirit Realty Capital, Inc.), Agreement (Spirit Realty Capital, Inc.), Spirit Realty, L.P.
In General. Except as otherwise provided in this Section 6.46.04, 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 of Partnership Common Units in the same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 6.02 and 6.3 6.03 hereof.
Appears in 3 contracts
Samples: Trade Street Residential, Inc., Trade Street Residential, Inc., Trade Street Residential, 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 of Partnership Common Units 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 hereof.
Appears in 3 contracts
Samples: Vintage Wine Trust Inc, Feldman Mall Properties, Inc., Feldman Mall Properties, 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 of Partnership Common Units 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 hereof6.3.
Appears in 3 contracts
Samples: BioMed Realty Trust Inc, BioMed Realty Trust Inc, BioMed Realty Trust Inc
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 6.3 6.4 hereof.
Appears in 2 contracts
Samples: Agreement (Vici Properties Inc.), Vici Properties Inc.
In General. Except as otherwise provided in this Section 6.4, for U.S. income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof.
Appears in 2 contracts
Samples: Invitation Homes Inc., Invitation Homes Inc.
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof.
Appears in 1 contract
Samples: International Market Centers, Inc.
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units in the LA\4346025.7 same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3 hereof.
Appears in 1 contract
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereofof this Agreement.
Appears in 1 contract
Samples: NewLake Capital Partners, 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 of Partnership Common Units 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 hereof.
Appears in 1 contract
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units in the LA\4346025.6 same manner as its correlative item of “book” income, gain, loss or deduction is allocated pursuant to Sections 6.2 and 6.3 hereof.
Appears in 1 contract
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof6.3.
Appears in 1 contract
Samples: Workspace Property Trust
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof.
Appears in 1 contract
Samples: MacKenzie Realty Capital, 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 of Partnership Common Units 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 hereof.
Appears in 1 contract
Samples: Westfield America Inc
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Treasury Regulations each Partnership item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders of Partnership Common Units 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 hereof.
Appears in 1 contract
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 of Partnership Common Units 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 hereof6.3.
Appears in 1 contract
Samples: Rayonier, L.P.
In General. Except as otherwise provided in this Section 6.46.04, 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 of Partnership Common Units in the same manner as its correlative item of “"book” " income, gain, loss or deduction is allocated pursuant to Sections 6.2 6.02 and 6.3 6.03 hereof.
Appears in 1 contract
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 of Partnership Common Units 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 hereof.
Appears in 1 contract
Samples: New Plan Excel Realty Trust Inc
In General. Except as otherwise provided in this Section 6.4, for income tax purposes under the Code and the Regulations each Partnership Partner- ship item of income, gain, loss and deduction (collectively, “"Tax Items”") shall be allocated among the Holders of Partnership Common Units 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 hereof.
Appears in 1 contract
Samples: Apartment Investment & Management Co
In General. Except as otherwise provided in this Section 6.46.5, for income tax purposes under the Code and the Regulations Regulations, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof.. 39
Appears in 1 contract
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 of Partnership Common Units 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 hereof.. B. Allocations Respecting Section 704(c)
Appears in 1 contract
Samples: Agreement (Price Reit Inc)
In General. Except as otherwise provided in this Section 6.4, for federal, state, and local income tax purposes under the Code and the Regulations purposes, each Partnership item of income, gain, loss and deduction (collectively, “Tax Items”) shall be allocated among the Holders of Partnership Common Units 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 hereof.
Appears in 1 contract
