REIT Election. Effective as of the date immediately after the Distribution Date, without the need for any further action by any party (except as otherwise required by applicable law), SpinCo hereby agrees to elect to be classified as a REIT for U.S. federal income tax purposes.
Appears in 2 contracts
Sources: Pre Spin Assignment, Assumption and Contribution Agreement (Millrose Properties, Inc.), Pre Spin Assignment, Assumption and Contribution Agreement (Millrose Properties, Inc.)
REIT Election. Effective as of the date immediately after the Distribution Date, without Without the need for any further action by any party (except as otherwise required by applicable law), SpinCo hereby agrees to elect to be classified as a REIT for U.S. federal income tax purposespurposes effective as of date immediately after the Distribution Date.
Appears in 2 contracts
Sources: Pre Spin Assignment, Assumption and Contribution Agreement (Millrose Properties, Inc.), Pre Spin Assignment, Assumption and Contribution Agreement (Millrose Properties, Inc.)