Section 704(c) Method. LVP shall use, and shall cause any other entity in which LVP has a direct or indirect interest to use, the “traditional method” under Treasury Regulation Section 1.704-3(b) without curative allocations for purposes of making allocations under Section 704(c) of the Code or reverse Section 704(c) allocations with respect to the Contributed Interest and the Properties to take into account the book-tax disparities as of the effective time of the Contribution with respect to the Contributed Interest and the Properties.
Appears in 4 contracts
Samples: Tax Protection Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.), Tax Protection Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.), Tax Protection Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.)
