SpinCo REIT Election. SpinCo (i) shall make an election to be taxed as a REIT under Sections 856-860 of the Code for its taxable year commencing on the date of Distribution and ending December 31, 2022 and (ii) shall jointly make a protective election with RemainCo to be treated as a TRS of RemainCo, in the case of each of clause (i) and this clause (ii), effective as of the date of the Distribution.
Appears in 2 contracts
Sources: Tax Matters Agreement (Bluerock Homes Trust, Inc.), Tax Matters Agreement (Bluerock Homes Trust, Inc.)