Disregard of Entity. Pursuant to Treasury Regulations § 301.7701-2(a), the Company shall be disregarded for federal income tax purposes because it has a single Member and shall be treated as a branch or division of its Member.
Appears in 7 contracts
Samples: Operating Agreement (LifeCare Holdings, Inc.), Operating Agreement (LifeCare Holdings, Inc.), Operating Agreement (LifeCare Holdings, Inc.)
Disregard of Entity. Pursuant to Treasury Regulations § 301.7701-2(a), the Company shall be disregarded for federal income tax purposes because it has a single Member Member, and shall be treated as a branch or division of its Member.
Appears in 1 contract
Samples: Company Agreement
Disregard of Entity. Pursuant to Treasury Regulations § 301.7701-2(a), the Company shall be disregarded for federal income tax purposes because it has a single Member Member, and shall be treated for federal income tax purposes (only) as a branch or division of its Member.
Appears in 1 contract