Considered a Partnership for Tax Purposes. The Members intend that, pursuant to the provisions of Subchapter K of Chapter 1 of Subtitle A of the Code and/or any comparable provision of applicable state law, beginning as of the Effective Date, the Company will be treated as a partnership for Federal, state and local income tax purposes. Each Member agrees not to make or attempt to make an election under Section 761 of the Code or to be excluded from the application of Subchapter K or from the application of any comparable provisions of applicable state law. The Company and the Members shall not elect classification of the Company for Federal tax purposes as other than a partnership under Regulations Section 301.7701-3 or for state and/or local tax purposes under such comparable provisions of applicable state or local law.
Appears in 7 contracts
Samples: Limited Liability Company Operating Agreement, Limited Liability Company Agreement (Carey Watermark Investors 2 Inc), Limited Liability Company Agreement (Carey Watermark Investors 2 Inc)
