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: Credit Agreement (Digital Realty Trust, L.P.), Constructive Ownership Definition (Digital Realty Trust, Inc.), Ii Contribution Agreement (Amb Property Corp)
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 (CoreSite Realty Corp), Agreement (Rexford Industrial Realty, Inc.), Contribution Agreement (City 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 Corp), 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 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 18 contracts
Samples: Agreement (Brixmor Property Group Inc.), Limited Partnership Agreement (Five Point Holdings, LLC), Agreement (Brixmor Operating Partnership 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: Assignment and Assumption Agreement (Amb Property Corp), Form of Agreement (Corporate Property Associates 18 Global Inc), Assignment and Assumption Agreement (Amb Property Corp)
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 (Colony NorthStar, Inc.), Limited Liability Company Agreement (Five Point Holdings, LLC), Limited Liability Company Agreement (Colony Financial, 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.), Aviv REIT, Inc., 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.), Purchase and Contribution Agreement (Skilled Healthcare Group, Inc.), Purchase and Contribution Agreement (Skilled Healthcare Group, 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: Limited Liability Company Agreement (Kimco Realty OP, LLC), Limited Liability Company Agreement (Kimco Realty Corp), Operating Agreement (Healthpeak Properties, Inc.)
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 6.46.3, 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: Business Combination Agreement (FG New America Acquisition Corp.), Operating Agreement (Biote Corp.), Letter Agreement (FTAC Athena Acquisition Corp.)
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 6.4, 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: Douglas Emmett Inc, Hartman Short Term Income Properties XX, Inc., Global Signal 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 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: Dupont Fabros Technology, Inc., Tarantula Ventures LLC
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 6.45.4, 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 2 contracts
Samples: Business Combination Agreement (FinTech Acquisition Corp. IV), Agreement (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” "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 6.4, 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 6.45.3, 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 6.46.5, 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 6.4, 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 6.4, ---------- 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, 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)
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 6.46.7, 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 6.4, ---------- 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