Appointment of Tax Matters Partner. The tax matters partner (the “TMP”), as referred to in Code Section 6231(a)(7), for the Partnership shall be the Company.
Appointment of Tax Matters Partner. The tax matters Partner ---------------------------------- ("TMP") for the Partnership shall be the General Partner.
Appointment of Tax Matters Partner. The General Partner is hereby ---------------------------------- designated, pursuant to Code Section 6231(a)(7) as the Partnership's Tax Matters Partner, and is responsible for acting as the liaison between the Partnership and the Internal Revenue Service ("Service"), and as the coordinator of the Partnership's actions pursuant to a Service tax audit of the Partner ship. In the event of an audit of the Partnership's income tax returns, the General Partner shall participate in, and retain at the expense of the Partnership, accountants and other professionals to participate in such audit and contest assertions by the auditing agent that may be materially adverse to the Partners or the Partnership. The General Partner shall have the duties of a tax matters partner as provided in the Code, in addition to such other duties as are provided under this Agreement. The General Partner shall be reimbursed by the Partnership for all expenses, costs and liabilities expended or incurred by the General Partner.
Appointment of Tax Matters Partner. The Board of Managers is hereby designated pursuant to Code Section 6231(a)(7) as the Company's "Tax Matters Partner," and is responsible for acting as the liaison between the Company and the IRS. The Tax Matters Partner shall have the duties of a tax matters partner as provided in the Code, in addition to such other duties as are provided under this Agreement. The Tax Matters Partner shall be reimbursed by the Company for all out-of-pocket expenses, costs and liabilities expended or incurred by the Tax Matters Partner in acting as the Company's Tax Matters Partner.
Appointment of Tax Matters Partner. If a REMIC election or elections has or have been made or will be made in respect of the Trust Fund or any other assets specified in such REMIC election or elections which assets secure the Bonds of a Series, the tax matters partner for each such REMIC and for all purposes of the Code shall be the Person designated as such in the related Series Supplement.
Appointment of Tax Matters Partner. The Managing Member ---------------------------------- shall be the "Tax Matters Partner" for the Company as defined in Section 6231(a)(7) of the Code. As Tax Matters Partner, the Managing Member shall have all of the rights, duties, obligations and powers of a Tax Matters Partner, as so defined, set forth in Sections 6221 through 6233 of the Code, but shall have no authority to bind the Capital Member.
Appointment of Tax Matters Partner. If the Company is subject to the rules set forth in Sections 6221 through 6233 of the Code, Xxxxxx Xxxxxxxx shall be the "Tax Matters Partner" for the Company as defined in Section 6231(a)(7) of the Code. As Tax Matters Partner, Xxxxxx Xxxxxxxx shall have all of the rights, duties, obligations and powers of a Tax Matters Partner, as so defined, set forth in Sections 6221 through 6233 of the Code.
Appointment of Tax Matters Partner. General Electric is hereby designated Tax Matters Partner (hereinafter "TMP") as defined in Section 6231(a)(7) of the Internal Revenue Code (as amended) (the "Code"). The TMP and the other Partners shall use their best efforts to comply with the responsibilities outlined in this Section 9.10 and in Sections 6221 through 6232 of the Code (including any Treasury regulations promulgated thereunder) and in doing so shall incur no liability to any other Partner. The following provisions shall be applicable to the TMP and the other Partners:
(a) The Partners shall furnish the TMP with such information (including information specified in Section 6230(e) of the Code) as it may reasonably request to permit it to provide the Internal Revenue Service with sufficient information to allow proper notice to the Partners in accordance with Section 6223 of the Code. The TMP shall keep the Partners informed of all audits or investigations of the Partnership and of all administrative and judicial proceedings, as required by Section 6223 of the Code, and shall furnish each Partner with a copy of each notice or other communication received by the TMP from the Internal Revenue Service (except such notices as are sent directly to the Partners by the Internal Revenue Service).
(b) If any Partner intends to file a notice of inconsistent treatment under Section 6222(b) of the Code, such Partner shall, at least thirty (30) days prior to the filing of such notice, notify the other Partners of such intent and the manner in which the Partner's intended treatment of a partnership item is (or may be) inconsistent with the treatment of that item by the Partnership.
(c) The TMP shall not enter into any extension of the period of limitations for making assessments on behalf of the other Partners without first securing the written consent of the other Partners.
(d) No Partner shall file, pursuant to Section 6227 of the Code, a request for an administrative adjustment of partnership items for any Partnership taxable year without first notifying the other Partners. If the other Partners agree with the requested adjustment, the TMP shall file the request for administrative adjustment on behalf of the Partnership. If unanimous consent is not obtained within thirty (30) days, or within the period required to file timely the request for administrative adjustment, if shorter, any Partner, including the TMP, may file a request for administrative adjustment on its own behalf.
(e) Any Partner intendin...
Appointment of Tax Matters Partner. The Class B Member or its designee shall be the “Tax Matters Partner” for the Company as defined in Section 6231(a)(7) of the Code. As Tax Matters Partner, the designated Member shall have all of the rights, duties, obligations and powers of a Tax Matters Partner, as so defined, set forth in Sections 6221 through 6233 of the Code. Each Member agrees to treat its Interest in the Company in a manner consistent with that prescribed by the Tax Matters Partner with respect to all federal, state and local tax matters.
Appointment of Tax Matters Partner. Except as otherwise provided in the related Terms Indenture, if an election has been made or will be made to treat the Trust Estate securing the Series or the Issuer as a REMIC, the Residual Interest Holders, by virtue of their ownership of the Residual Interest, agree to designate the manager as the tax matters partner for the REMIC for all purposes of the Code and the Manager, as such, will perform, or cause to be performed, such duties and take, or cause to be taken, such actions as are required to be performed or taken by the tax matters partner under the Code or, to the extent not required by the Code, as the Manager, in its judgment, shall consider advisable and in the best interests of the REMIC.
