Extract to table

the adjusted purchase price of $1,098,930,000) must be allocated among the acquired assets using the "residual method" prescribed by IRC Section 338(b)(5) and the regulations thereunder

Allocation of Assumed Debt Among Properties The total assumed mortgage indebtedness of $612,000,000 forms part of the aggregate consideration for the transaction and must be allocated among the properties secured by each respective loan facility

Methodology for Allocating Within Each Property For each of the 14 properties, the allocated purchase price determined on a property-level basis (as set forth in Part V above) must be further subdivided among the Section 1060 asset classes to establish the buyer's tax basis in each category of acquired assets

Under IRC Section 856(c)(4), at least 75% of a REIT's total assets at the close of each calendar quarter must consist of real estate assets, cash, cash items, and government securities

The allocated purchase prices must be used consistently across federal and state filings to avoid audit risk and potential penalties

In particular, the Georgia, Florida, and Tennessee properties may be subject to reassessment following the recording of controlling interest transfer tax returns, which in some jurisdictions must disclose the consideration paid