Section 704(c) Method. The Operating Partnership shall use the “remedial method” described in Treasury Regulation § 1.704-3(d) for purposes of making allocations under Section 704(c) of the Code with respect to any book-tax disparities in connection with the Contributed Interests and underlying Properties at the time of their contribution to the Operating Partnership.
Appears in 6 contracts
Samples: Contribution Agreement (Paramount Group, Inc.), Contribution Agreement (Paramount Group, Inc.), Contribution Agreement (Paramount Group, Inc.)