Certain Tax Elections. The Company shall not file any election pursuant to Regulations Section 301.7701-3(c) to be treated as an entity other than a partnership. The Company shall not elect, pursuant to Code Section 761(a), to be excluded from the provisions of subchapter K of the Code.
Appears in 2 contracts
Samples: Subscription Agreement (Blockchain Industries, Inc.), Subscription Agreement (Blockchain Industries, Inc.)
Certain Tax Elections. The Company shall not not, without the consent of a majority of the Board of Managers, file any election pursuant to Regulations Section 301.7701-3(c) of the Regulations to be treated as an entity other than a partnershippartnership (a "Conversion Election"). The Company shall not elect, pursuant to Code Section 761(a)) of the Code, to be excluded from the provisions of subchapter K of the Code.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (NextWave Wireless LLC), Limited Liability Company Agreement (NextWave Wireless LLC)
Certain Tax Elections. The Company shall not file any election pursuant to Regulations Section 301.7701-3(c) to be treated as an entity other than a partnership. The Company shall not elect, pursuant to Code Section 761(a)) of the Code, to be excluded from the provisions of subchapter K of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Darling International Inc)
Certain Tax Elections. The Company shall not not, without the consent of the Board of Managers, file any election pursuant to Regulations Regulation Section 301.7701-3(c) to be treated as an entity other than a partnership. The Company shall not elect, pursuant to Code Section 761(a)) of the Code, to be excluded from the provisions of subchapter K of the Code.
Appears in 1 contract
Samples: LLC Interest Purchase Agreement (Mister Goody, Inc.)
Certain Tax Elections. The Company shall not not, without the consent of a majority of the Board of Managers, file any election pursuant to Regulations Section 301.7701-3(c) of the Regulations to be treated as an entity other than a partnershippartnership (a “Conversion Election”). The Company shall not elect, pursuant to Code Section 761(a)) of the Code, to be excluded from the provisions of subchapter K of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement (NextWave Wireless LLC)
Certain Tax Elections. The Except in connection with actions taken in accordance with Section 11.1, the Company shall not file any election pursuant to Regulations Section 301.7701-3(c) to be treated as an entity other than a partnership. The Company shall not partnership or elect, pursuant to Code Section 761(a), to be excluded from the provisions of subchapter K of the Code.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Solid Biosciences, LLC)
