Purpose: |
TALY REALTY QOF LLC HAS BEEN ORGANIZED AS A LIMITED LIABILITY COMPANY UNDER THE DELAWARE LIMITED LIABILITY COMPANY ACT AS OF SEPTEMBER 17, 2024. THE BUSINESS PURPOSE OF TALY REALTY QOF LLC IS (A) TO QUALIFY (AND MAINTAIN ITS QUALIFICATION) AS A “QUALIFIED OPPORTUNITY FUND” (WITHIN THE MEANING OF SECTION 1400Z-2(D) OF THE CODE) AND, IN FURTHERANCE THEREOF, (I) TO MAKE ANY ELECTION AND FILE ANY FORMS TO SO QUALIFY (AND MAINTAIN ITS QUALIFICATION), (II) TO DIRECTLY OR INDIRECTLY ACQUIRE, OWN, LEASE, DEVELOP, REDEVELOP, MANAGE, DISPOSE OF AND OTHERWISE DEAL WITH INVESTMENTS THAT ARE “QUALIFIED OPPORTUNITY ZONE PROPERTIES” (WITHIN THE MEANING OF SECTION 1400Z-2(D) OF THE CODE), WHETHER IN THE FORM OF “QUALIFIED OPPORTUNITY ZONE STOCK,” “QUALIFIED OPPORTUNITY ZONE PARTNERSHIP INTERESTS” OR “QUALIFIED OPPORTUNITY ZONE BUSINESS PROPERTIES” (EACH WITHIN THE MEANING OF SECTION 1400Z-2(D) OF THE CODE) (ANY SUCH INVESTMENTS COLLECTIVELY REFERRED TO AS “INVESTMENTS,” AND (III) TO ENGAGE IN SUCH ACTIVITIES AS ARE RELATED OR INCIDENTAL TO THE FOREGOING INCLUDING THE ACQUISITION, OWNERSHIP, OPERATION, FINANCING, REFINANCING, MANAGEMENT, MAINTENANCE, RENOVATION, DEVELOPMENT, REDEVELOPMENT, IMPROVEMENT, CONSTRUCTION, LEASING, SALE AND/OR OTHER DISPOSITION OF THE INVESTMENTS AND TO DO SUCH OTHER ACTS AND TO OWN SUCH OTHER ASSETS AS THE MANAGER MAY DEEM NECESSARY OR ADVISABLE IN CONNECTION WITH, IN SUPPORT OF OR INCIDENTAL TO THE FOREGOING. THE COMPANY SHALL HAVE THE POWER AND AUTHORITY TO TAKE ANY AND ALL ACTIONS NECESSARY, APPROPRIATE, PROPER, ADVISABLE, CONVENIENT OR INCIDENTAL TO OR FOR THE FURTHERANCE OF THE PURPOSES SET FORTH HEREIN. THE COMPANY IS AUTHORIZED TO ENTER INTO, MAKE, AND PERFORM ALL CONTRACTS AND OTHER UNDERTAKINGS, AND ENGAGE IN ALL OTHER ACTIVITIES AND TRANSACTIONS, AS THE MANAGER MAY DEEM NECESSARY, ADVISABLE, OR CONVENIENT FOR CARRYING OUT THE PURPOSES OF THE COMPANY. |