Precontribution Gain definition

Precontribution Gain has the meaning set forth in subparagraph 4(c) of Exhibit B.

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Precontribution Gain has the meaning set forth in Section 5.01(f)(iii).

Precontribution Gain shall have the meaning set forth in Exhibit B.

Examples of Precontribution Gain in a sentence

• The intent of this subparagraph 4(c) is that each Partner who contributed to the capital of the Partnership a Contributed Property will bear, through reduced allocations of depreciation, increased allocations of gain or other items, the tax detriments associated with any Precontribution Gain.

• The intent of this subparagraph 3(c) is that each Partner who contributed to the capital of the Partnership a Contributed Property will bear, through reduced allocations of depreciation, increased allocations of gain or other items, the tax detriments associated with any Precontribution Gain.

• The intent of this Section 5.01(f)(iii) is that each Partner who contributed to the capital of the Partnership a Contributed Property will bear, through reduced allocations of depreciation, increased allocations of gain or other items, the tax detriments associated with any Precontribution Gain.

• If any portion of the property distributed consists of property which had been contributed by the distributee member to the Company, then such property shall not be taken into account under this Article and shall not be taken into account in determining the amount of the Net Precontribution Gain.

• The Net Precontribution Gain means the net gain (if any) which would have been recognized by the distributee member under Section 704(c)(1)(B) of the Code if all property which (A) had been contributed to the Company within seven years of the distribution, and (B) is held by the Company immediately before the distribution, had been distributed by the Company to another member.

More Definitions of Precontribution Gain

Precontribution Gain has the meaning set forth in Section 3(c) of Appendix II.

Precontribution Gain has the meaning set forth in subparagraph 3(c) of Exhibit A.

Precontribution Gain means, with respect to each Shopping Center Project owned by an existing Property Partnership, that unrealized gain attributable to the excess of (a) the fair market value of such Shopping Center Project on April 15, 1993, over (b) the adjusted tax basis of such Shopping Center Project on such date; provided, however, that the amount of any Precontribution Gain associated with a Shopping Center Project shall be adjusted to account for allocations made in accordance with the provisions of Section 3(c) of this Exhibit C and shall not, in any event, exceed that amount of gain actually allocated to the Partnership by the Property Partnership as a result of the sale or other disposition of such Shopping Center Project.

Precontribution Gain means with respect to any Acceptable Security which a Shareholder contributes to the Fund, (i) the excess of the Exchange Value of such Acceptable Security over its tax basis in the hands of the Fund immediately after such contribution on the date of contribution or, if less, (ii) the excess of the amount realized on a sale or other taxable disposition of such Acceptable Security by the Fund, the Company or the Portfolio over its tax basis.

Precontribution Gain has the meaning set forth in Section 5.1(i)(iii) hereof.

Precontribution Gain means with respect to any Acceptable Security that a Shareholder contributes to the Fund, (i) the excess of the Exchange Value of such Acceptable Security over its tax basis in the hands of the Fund immediately after such contribution on the date of contribution or, if less, (ii) the excess of the amount realized on a sale or other taxable disposition of such Acceptable Security by the Fund, the Company or the Portfolio over its tax basis.

Precontribution Gain shall have the meaning set forth in Exhibit C. "Prime Rate" shall mean the prime rate announced from time to time by Well▇ ▇▇▇go Bank, N.A. or any successor thereof. "Property" shall mean any Shopping Center Project in which the Partnership or any Property Partnership, directly or indirectly, acquires ownership of a fee or leasehold interest. "Property Manager" shall mean General Growth Management, Inc., a Delaware corporation, or its permitted successors or assigns. "Property Partnership" shall mean and include any partnership, limited liability company or other Entity in which the Partnership directly or indirectly is or becomes a partner, member or other equity participant and which has been or is formed for the purpose of directly or indirectly acquiring, developing or owning a Property or a proposed Property. "Property Partnership Interests" shall mean and include the interest of the Partnership as a partner, member or other equity participant in any Property Partnership. "Qualified Individual" shall have the meaning set forth in Section 12.2 hereof. "Regulations" shall mean the final, temporary or proposed Income Tax Regulations promulgated under the Code, as such regulations may be amended from time to time (including corresponding provisions of succeeding regulations). "Regulatory Allocations" shall have the meaning set forth in Exhibit C. "REIT" shall mean a real estate investment trust as defined in Section 856 of the Code. "REIT Expenses" shall mean (i) costs and expenses relating to the formation and continuity of existence of the General Partner and its subsidiaries (which subsidiaries shall, for purposes of this definition, be included within the definition of General Partner), including taxes, fees and assessments associated therewith, any and all costs, expenses or fees payable to any director or trustee of the General Partner or such subsidiaries, (ii) costs and expenses relating to any offer or registration of securities by the General Partner and all statements, reports, fees and expenses incidental thereto, including underwriting discounts and selling commissions applicable to any such offer of securities, (iii) costs and expenses associated with the preparation and filing of any periodic reports by the General Partner under federal, state or local laws or regulations, including filings with the SEC, (iv) costs and expenses associated with compliance by the General Partner with laws, rules and regulations promulgated by any regulatory b...