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. 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. 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
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. The General Partner shall timely file with the Internal Revenue Service an "Entity Classification Election" (Form 8832) on behalf of the Limited Partnership, effective as of November 25, 2002, therein electing for the Limited Partnership to be treated as an association taxable as a corporation.
Entity Classification Election. The parties shall cause the Ivanhoe Contributee to make, not later than October 31, 2006, a “check-the-box” election to treat the Ivanhoe Contributee as a partnership for US tax purposes and all of them shall cooperate with each other to facilitate the making of such election. Ivanhoe Holdings shall not take any steps with respect to such election as would have adverse effect on Jahold, Golober or any other Xxxxx Entity.
