TRS Election. Without the need for any further action by any party (except as otherwise required by applicable law), TRSCo and SpinCo each hereby agree for TRSCo to elect to be classified as a taxable REIT subsidiary for U.S. federal income tax purposes 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.)
TRS Election. Without 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), TRSCo and SpinCo each hereby agree for TRSCo to elect to be classified as a taxable REIT subsidiary for U.S. federal income tax purposes effective as of date immediately after the Distribution Datepurposes.
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.)