Federal Income Tax Elections. All elections required or permitted to be made by the Company under the Code shall be made by the Managers as determined in their sole discretion. For all purposes permitted or required by the Code, the Members constitute and appoint the Manager as the “tax matters partner” (or “partnership representative” as that term is used in Code Section 6223 for partnership tax years beginning after December 31, 2017) or such other managing Member as shall be designated by a Majority Interest of the Members.
Appears in 7 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
Federal Income Tax Elections. All elections required or permitted to be made by the Company under the Code shall be made by the Managers as determined in their sole discretion. For all purposes permitted or required by The provisions on limitations of liability of the Code, the Members constitute Managers and appoint the Manager as the “tax matters partner” (or “partnership representative” as that term is used indemnification set forth in Code Section 6223 for partnership tax years beginning after December 31, 2017) or such other managing Member as Article V hereof shall be designated by a Majority Interest of the Membersfully applicable to each Manager in its capacity as tax partner.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Commerce Street Pantheon Mortgage Asset Securitizations LLC)