Federal Income Tax Characterization. For federal income tax purposes, the Company shall be deemed to have a single “member” (as such term is used in the regulations under Section 7701 of the Internal Revenue Code of 1986, as amended) and is intended to be disregarded as a separate entity for federal income tax purposes (and solely for such purposes) pursuant to such Section 7701 and the regulations thereunder.
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Xm Investment LLC), Limited Liability Company Operating Agreement (ET Wayne Finance, L.L.C.), Limited Liability Company Agreement (Xm Investment LLC)
Federal Income Tax Characterization. For federal income tax purposes, the Company shall be deemed to have a single “"member” " (as such term is used in the regulations under Section 7701 of the Internal Revenue Code of 1986, as amended) and is intended to be disregarded as a separate entity for federal income tax purposes (and solely for such purposes) pursuant to such Section 7701 and the regulations thereunder.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Apple Hospitality Two Inc)
