Classification as a Corporation. The Company shall elect to be classified as a corporation under Section 7701(a)(3) of the Internal Revenue Code and Treas. Reg. §301.7701-2(b).
Classification as a Corporation. The parties hereto intend the Company to be classified as an association taxable as a corporation for U.S. federal, state and local tax purposes effective as of August 29, 2024, and the Company has made (or shall make) an election to be classified as a corporation for U.S. federal income tax purposes effective as of August 29, 2024. Unless otherwise determined by the Board of Directors, and subject to the applicable consent rights specified in Section 6.11, the Company shall take (or refrain from taking) such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent therewith. Each Member shall reasonably cooperate with the Company in connection with the foregoing provisions of this Section 8.1 and agrees to refrain from taking any actions inconsistent with such classification without the written consent of the Board of Directors.
Classification as a Corporation. The parties hereto intend the Partnership be classified as a corporation for U.S. federal income tax purposes. The General Partner shall, for and on behalf of the Partnership, shall file an initial entity classification election on IRS Form 8832 to treat the Partnership as a corporation and shall be permitted to take all steps as may be required or advisable to maintain the Partnership’s classification as a corporation as of the date of formation of the Partnership. The Partnership’s books of account shall be maintained on a basis consistent with such treatment, and the Partners hereby agree to take any measures necessary (or, if applicable, refrain from any action) to ensure that the Partnership is treated as a corporation for U.S. federal, state and local income tax purposes.
Classification as a Corporation. The Members and the Managing Member intend that the Company be classified as an association taxable as a corporation for all U.S. federal and state income tax purposes, and the Managing Member and each Member shall treat the Company as an association taxable as a corporation for U.S. federal and state income tax purposes.
Classification as a Corporation. The Sole Member intends that the Company be classified as an association taxable as a corporation for all U.S. federal and state income tax purposes, and the Sole Member shall consistently treat the Company as an association taxable as a corporation for U.S. federal and state income tax purposes. The Sole Member agrees to timely file IRS Form 8832 to effect the Company’s election to be classified as a corporation effective as of July 10, 2024.
