Entity Classification Election. The Company shall execute and file a U.S. Internal Revenue Service Form 8832 electing to classify the Company as a corporation for U.S. federal income tax purposes pursuant to Treasury Regulation Section 301.7701-3 as of a date no later than the date hereof, and each Officer of the Company and each Director is hereby authorized to execute and file such Form 8832 for all of the Members. The Company is hereby authorized to execute and file for all of the Members any comparable form or document required by any applicable United States state or local income or similar tax law for the Company to be classified as a corporation under such tax law.
Entity Classification Election. The Fund shall execute and file a U.S. Internal Revenue Service Form 8832 electing to classify the Fund as a corporation for U.S. federal income tax purposes pursuant to Treasury Regulation Section 301.7701-3 as of a date no later than the date hereof, and each Officer of the Fund and each Director is hereby authorized to execute and file such Form 8832 for all of the Members. The Fund is hereby authorized to execute and file for all of the Members any comparable form or document required by any applicable United States state or local income or similar tax law for the Fund to be classified as a corporation under such tax law.
Entity Classification Election. Neither the Company nor any Member may make an election for the Company to be treated as an association taxable as a corporation for U.S. federal income tax purposes, and no provision of this Agreement will be construed to sanction or approve such an election.
Entity Classification Election. The Company shall at all times have more than one member and be classified as a partnership for federal income tax purposes. The Company shall not file any election to be classified as other than a partnership for federal tax purposes.
Entity Classification Election. To the extent permitted by applicable Law, on the Closing Date, NuStar GP shall file IRS Form 8832 electing to be classified as an entity disregarded as separate from its owner, effective on the Closing Date.
Entity Classification Election. With respect to the acquisition of the Olsy Shares, the Olsy Japan Shares, the Olsy Brazil Shares and the capital stock of any Controlled Subsidiary pursuant to this Agreement, at the sole option and discretion of Wang and with the assumption of and payment by Wang of all costs, expenses or damages payable by Olivetti as a result of or attributable thereto, Olivetti, prior to the Closing Date, shall make an election under Treasury Regulations section 301.7701-3(c) to have Olsy, Olsy Japan, Olsy Brazil or any Controlled Subsidiary classified as a partnership or disregarded as a separate entity for United States federal income tax purposes.
Entity Classification Election. The Parties (other than the Investors), will not, and will cause the other Group Companies not to, take any action inconsistent with their treatment as corporations for U.S. federal income tax purposes without the prior written consent of Investor Directors and will not elect to be treated as other than corporations for U.S. federal income tax purposes. Upon notification by Investor Directors that any Group Company should elect to be classified as partnerships or disregarded entities for United States federal income tax purposes (the “Partnership Election”), the Parties (other than the Investors), if applicable, shall make, or shall cause to be made, the “Partnership Election” by filing, or by causing to be filed, Internal Revenue Service Form 8832 (or any successor form), and the Parties (other than the Investors), shall not permit the Partnership Election to be terminated or revoked without the written consent of Investor Directors.
Entity Classification Election. Prior to the Closing, Target will deliver to Parent a signed IRS Form 8832, Entity Classification Election, with respect to the entities set forth on Schedule 6.9 (the “Electing Entities”), consenting to an election by each of such Electing Entities to be disregarded as an entity separate from its sole owner effective on the day prior to the Effective Time.
Entity Classification Election. (i) Seller and Buyer shall promptly, and shall promptly cause any of their applicable Affiliates (including the Target Company) to, make or cause to be made a timely entity classification election pursuant to U.S. Treasury Regulation Section 301.7701-3(c) having an effective date as of the Closing Date and electing partnership status with respect to the Target Company (the “Entity Classification Election”). At least ten (10) days prior to the Closing, Seller shall deliver to Buyer all applicable IRS Forms 8832 (and all other forms or documents required to effect the Entity Classification Election) duly completed and executed (except for execution by Buyer or applicable Affiliate of Buyer) and in a form acceptable to Buyer (the “Entity Classification Election Forms”)༎Within seventy-five (75) days after the Closing Date, Buyer will duly execute the Entity Classification Election Forms, as applicable, and promptly deliver to Seller a copy of each such duly executed Entity Classification Election Form.
Entity Classification Election. Following the Closing, Buyer shall cause the Company to timely file with the United States Internal Revenue Service the Form 8832 (Entity Classification Election) executed by Buyer and Seller pursuant to Section 2.7(a)(xix).
