Elections and Consents. (a) Time and manner of making elections.
Elections and Consents. (a) Time and manner of making elec- tions—(1) In general. An election state- ment made under this section must identify the election being made, set forth the name, address, and taxpayer identification number of the corpora- tion, and be signed by a person author- ized to sign the return required to be filed under section 6037.
Elections and Consents. The election required by Section 5.02(b) and the consent required by Section 5.02(c)must be submitted to the Employer:
Elections and Consents. No elections with respect to the Company's Taxes that are adverse to the Company are in effect. No election under Section 1362 of the Code relating to taxation as an S corporation is in effect with respect to the Company. The Company has not filed a consent pursuant to Section 341(f) of the Code relating to collapsible corporations, nor has it agreed to have Section 341(f)(2) of the Code apply to any disposition of a subsection (f) asset (as such term is defined in Section 341(f)(4) of the Code). The Company has not made any payments, is not obligated to make any payments, and is not a party to any agreement that under certain circumstances could obligate it to make any payments that will not be deductible under Section 280G of the Code. The Company is not a party to any Tax allocation or sharing agreement. The Company has never been a member of an affiliated group filing a consolidated federal income Tax return and has no liability for the Taxes of an person under Treasury regulation section 1.1502-6 (or any similar provision of state, local, or foreign law), as a transferee or successor by contract, or otherwise.
Elections and Consents. No federal tax elections under the Code, including any election under Section 1362 of the Code relating to taxation as an S corporation, are in effect with respect to the Company. The Company has not filed a consent pursuant to Section 341(f) of the Code relating to collapsible corporations, nor has it agreed to have Section 341(f)(2) of the Code apply to any disposition of a subsection (f) asset (as such term is defined in Section 341(f)(4) of the Code).
Elections and Consents. Neither the Company nor any of its Subsidiaries has filed a consent pursuant to Section 341(f) of the Code relating to collapsible corporations, nor has the Company or any of its Subsidiaries agreed to have Section 341(f)(2) of the Code apply to any disposition of a subsection (f) asset (as such term is defined in Section 341(f)(4) of the Code). Neither the Company nor any of its Subsidiaries has made any payments, is obligated to make any payments, or is a party to any agreement that under certain circumstances could obligate it to make any payments that will not be deductible under Section 280G of the Code. Neither the Company nor any of its Subsidiaries has been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code. Each of the Company and its Subsidiaries has disclosed on its United States income Tax Returns all positions taken therein that could give rise to a substantial understatement of federal income Tax within the meaning of Section 6662 of the Code. Neither the Company nor any of its Subsidiaries is a party to any Tax allocation or Tax sharing agreement. None of the Company and its Subsidiaries has been a member of an affiliated group filing a consolidated United States income Tax Return. Neither the Company nor any of its Subsidiaries has any material liability for the Taxes of any Person (other than the Company and its Subsidiaries) under Treasury Regulation Section 1.1502-6 (or any similar provision of any other Applicable Law), as a transferee or successor, by contract, or otherwise. 3.11.6.
Elections and Consents. Neither the Company nor any Company Sub has filed a consent under Code §341(f) concerning collapsible corporations. Neither the Company nor any Company Sub has made any payments, is obligated to make any payments, or is a party to any agreement that under certain circumstances would obligate it to make any payments that will not be deductible under Code §280G. Neither the Company nor any Company Sub has been a United States real property holding corporation within the meaning of Code §897(c)(2) during the applicable period specified in Code §897(c)(1)(A)(ii). The Company and each Company Sub has disclosed on its federal income Tax Returns all positions taken therein that would give rise to a substantial understatement of federal income Tax within the meaning of Code §6662. Neither the Company nor any Company Sub is a party to any Tax allocation or sharing agreement. Neither the Company nor any Company Sub (A) has ever been a member of an Affiliated Group filing a consolidated federal income Tax Return and (B) has any liability for the Taxes of any person under Treasury Regulation §1.1502-6 (or any similar provision of state, local, or foreign law), as a transferee or successor, by contract, or otherwise.
