Allocation Conventions. Any Tax Item of NLOP or any member of the NLOP Group arising from a transaction engaged in outside of the ordinary course of business on the Distribution Date after the Effective Time shall be properly allocable to NLOP and any such transaction by or with respect to NLOP or any member of the NLOP Group occurring after the Effective Time shall be treated for all Tax purposes (to the extent permitted by applicable Tax Law) as occurring at the beginning of the day following the Distribution Date in accordance with the principles of Treasury Regulation § 1.1502-76(b) or any similar provisions of state, local or non-U.S. Law.
Appears in 3 contracts
Sources: Tax Matters Agreement (W. P. Carey Inc.), Tax Matters Agreement (Net Lease Office Properties), Tax Matters Agreement (Net Lease Office Properties)