Election into TEFRA. In the event that the Company is not subject to the consolidated audit rules of Sections 6221 through 6234 of the Code during any fiscal year, each Person who was a Member at any time during such fiscal year hereby agrees to sign an election pursuant to Section 6231(a)(1)(B)(ii) of the Code and Regulations Section 301.6231(a)(1) 1(b)(2) to be filed with the Company’s federal income tax return for such fiscal year to have such consolidated audit rules apply to the Company.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Vantiv, Inc.), Limited Liability Company Agreement (Vantiv, Inc.), Limited Liability Company Agreement (Fifth Third Bancorp)
Election into TEFRA. In the event The Members intend that the Company is not be subject to the consolidated audit rules of Sections 6221 through 6234 of the Code during any fiscal yeareach Taxable Year. Accordingly, each Person who was a Member at any time during such fiscal year the Company’s first Taxable Year hereby agrees to sign an election pursuant to Section 6231(a)(1)(B)(ii) of the Code and Treasury Regulations Section 301.6231(a)(1) 1(b)(2301.6231(a)(1)-1(b)(2) to be filed with the Company’s federal income tax return for such fiscal year Taxable Year to have such consolidated audit rules apply to the Company.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Woodward, Inc.), Contribution Agreement (Woodward, Inc.)
Election into TEFRA. In the event that the Company is not subject to the consolidated audit rules of Sections 6221 through 6234 of the Code Pre-Amendment Code, during any fiscal yearFiscal Year, then so long as such rules remain in effect, each Person who was a Member at any time during such fiscal year Fiscal Year hereby agrees to sign an election pursuant to Section 6231(a)(1)(B)(ii) of the Pre-Amendment Code and Section 301.6231(a)(1)-1(b)(2) of the Regulations Section 301.6231(a)(1) 1(b)(2) thereunder, to be filed with the Company’s federal income tax return for such fiscal year Fiscal Year to have such consolidated audit rules apply to the Company.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Charter Communications, Inc. /Mo/)
Election into TEFRA. In the event that the Company is not subject to the consolidated audit rules of Sections 6221 through 6234 of the Code during any fiscal yearFiscal Year, each Person who was a Member at any time during such fiscal year Fiscal Year hereby agrees to sign an election pursuant to Section 6231(a)(1)(B)(ii) of the Code and Regulations Section 301.6231(a)(1) 1(b)(2301.6231(a)(1)-1(b)(2) to be filed with the Company’s United States federal income tax return for such fiscal year Fiscal Year to have such consolidated audit rules apply to the Company.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Realnetworks Inc)
Election into TEFRA. In the event that the Company is not subject to the consolidated audit rules of Sections 6221 through 6234 of the Code during any fiscal year, each Person who was a Member at any time during such fiscal year hereby agrees to sign an election pursuant to Section 6231(a)(1)(B)(ii) of the Code and Regulations Section 301.6231(a)(1) 1(b)(2301.6231(a)(1)1(b)(2) to be filed with the Company’s federal income tax return for such fiscal year to have such consolidated audit rules apply to the Company.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Total System Services Inc)
Election into TEFRA. In the event that the Company is not subject to the consolidated audit rules of Sections 6221 through 6234 of the Code during any fiscal year, each Person who was a Member at any time during such fiscal year hereby agrees to sign an election pursuant to Section 6231(a)(1)(B)(ii) of the Code and Regulations Section 301.6231(a)(1) 1(b)(2) to be filed with the Company’s federal income tax return for such fiscal year to have such consolidated audit rules apply to the Company.. 44
Appears in 1 contract
Samples: Limited Liability Company Agreement
