Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 28 contracts
Samples: Loan and Servicing Agreement (SLR Investment Corp.), Loan and Servicing Agreement (KKR Real Estate Finance Trust Inc.), Loan and Servicing Agreement (Carlyle Secured Lending III)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 27 contracts
Samples: Loan and Servicing Agreement (FS KKR Capital Corp), Loan and Servicing Agreement (FS KKR Capital Corp), Loan and Servicing Agreement (GOLUB CAPITAL BDC, Inc.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b3(b)(ii), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 11 contracts
Samples: Loan and Servicing Agreement (Antares Private Credit Fund), Loan and Servicing Agreement (HPS Corporate Lending Fund), Loan and Servicing Agreement (Diameter Credit Co)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Regulations Section 301.7701-3(b3(b)(ii), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Regulations Section 301.7701-3(c).
Appears in 5 contracts
Samples: Loan and Servicing Agreement (First Eagle Private Credit Fund), Loan and Servicing Agreement (AG Twin Brook Capital Income Fund), Loan and Servicing Agreement (First Eagle Private Credit Fund)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, being treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 3 contracts
Samples: Loan and Servicing Agreement (Solar Capital Ltd.), Consent and Omnibus Amendment (Solar Capital Ltd.), Consent and Omnibus Amendment (Solar Senior Capital Ltd.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b301.7701‐3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c301.7701‐3(c).
Appears in 2 contracts
Samples: Loan and Servicing Agreement (Carlyle Credit Solutions, Inc.), Loan and Servicing Agreement (Carlyle Credit Solutions, Inc.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b)for U.S. federal income tax purposes, and neither none of the Borrower Borrower, the Equityholder, nor any other Person on its their behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 2 contracts
Samples: Loan and Servicing Agreement (FS KKR Capital Corp), Loan and Servicing Agreement (FS Investment Corp II)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to beelection, or take any other action that is reasonably likely would cause the Borrower, to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 2 contracts
Samples: Loan and Servicing Agreement (North Haven Private Income Fund LLC), Loan and Servicing Agreement (North Haven Private Income Fund LLC)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in may cause the Borrower being, to be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c)owner.
Appears in 2 contracts
Samples: Loan and Servicing Agreement (Franklin BSP Lending Corp), Loan and Servicing Agreement (Business Development Corp of America)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b301.7701‑3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c301.7701‑3(c).
Appears in 1 contract
Samples: Loan and Servicing Agreement (KKR Real Estate Finance Trust Inc.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b301.7701‐3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c301.7701‐3(c).. (x)
Appears in 1 contract
Samples: Loan and Servicing Agreement (Carlyle Secured Lending III)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Regulations Section 301.7701-3(b301.7701‑3(b)(ii), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Regulations Section 301.7701-3(c301.7701‑3(c).
Appears in 1 contract
