Tax Agreement. In accordance with Section 704(c) of the Code, the Operating Partnership shall adopt and use only the so-called "traditional method" described in Treasury Regulation Section 1.704-3(b) with respect to any properties transferred directly or indirectly by the Fund to the Operating Partnership as a result of the Formation Transactions, and therefore shall not make any curative or remedial allocations with respect to such properties.
Appears in 7 contracts
Samples: Agreement and Plan of Merger (Douglas Emmett Inc), Agreement and Plan of Merger (Douglas Emmett Inc), Agreement and Plan of Merger (Douglas Emmett Inc)
Tax Agreement. In accordance with Section 704(c) of the Code, the Operating Partnership shall adopt and use only the so-so called "traditional method" described in Treasury Regulation Section 1.704-3(b) with respect to any properties transferred directly or indirectly by the Fund Partnership to the Operating Partnership as a result of the Formation Transactions, and therefore shall not make any curative or remedial allocations with respect to such properties.. ARTICLE VII
Appears in 6 contracts
Samples: Agreement and Plan of Merger (Douglas Emmett Inc), Agreement and Plan of Merger (Douglas Emmett Inc), Agreement and Plan of Merger (Douglas Emmett Inc)
Tax Agreement. In accordance with Section 704(c) of the Code, the Operating Partnership shall adopt and use only the so-called "traditional method" described in Treasury Regulation Section 1.704-3(b) with respect to any properties transferred directly or indirectly by the Fund to the Operating Partnership as a result of the Formation Transactions, and therefore shall not make any curative or remedial allocations with respect to such properties.. ARTICLE VII
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Douglas Emmett Inc), Agreement and Plan of Merger (Douglas Emmett Inc)
Tax Agreement. In accordance with Section 704(c) of the Code, the Operating Partnership shall adopt and use only the so-so called "traditional method" described in Treasury Regulation Section 1.704-3(b) with respect to any properties transferred directly or indirectly by the Fund Partnership to the Operating Partnership as a result of the Formation Transactions, and therefore shall not make any curative or remedial allocations with respect to such properties.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Douglas Emmett Inc), Agreement and Plan of Merger (Douglas Emmett Inc)
Tax Agreement. In accordance with Section 704(c) of the Code, the Operating Partnership shall adopt and use only the so-called "traditional method" described in Treasury Regulation Section 1.704-3(b) with respect to any properties transferred directly or indirectly by the Fund to the Operating Partnership as a result of the Formation Transactions, and therefore shall not make any curative or remedial allocations with respect to such properties.the
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Douglas Emmett Inc), Agreement and Plan of Merger (Douglas Emmett Inc)
Tax Agreement. In accordance with Section 704(c) of the Code, the Operating Partnership shall adopt and use only the so-called "traditional method" described in Treasury Regulation Section 1.704-3(b) with respect to any properties transferred directly or indirectly by the Fund to the Operating Partnership as a result of the Formation TransactionsPLE Shares, and therefore shall not make any curative or remedial allocations with respect to such properties.allocations. ARTICLE VI
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