Intent for Income Tax Purposes. The Members intend that the Company be treated as a partnership for federal, state and local income tax purposes and that it be operated in a manner consistent with such treatment, but that the Company not be operated or treated as a “partnership” for any other purpose, including, but not limited to, Section 303 of the Federal Bankruptcy Code, and the provisions of this Agreement may not be construed to suggest otherwise. The Members intend that the Facility Company be treated as a disregarded entity for federal, state and local tax purposes.
Appears in 11 contracts
Samples: Operating Agreement (Bloom Energy Corp), Operating Agreement (Bloom Energy Corp), Operating Agreement (Bloom Energy Corp)
Intent for Income Tax Purposes. The Members intend that the Company be treated as a partnership for federal, state and local income tax purposes and that it be operated in a manner consistent with such treatment, but that the Company not be operated or treated as a “partnership” for any other purpose, including, but not limited to, Section 303 of the Federal Bankruptcy Code, and the provisions of this Agreement may not be construed to suggest otherwise. The Members intend that the Facility Company be treated as a disregarded entity for federal, state and local tax purposes.
Appears in 8 contracts
Samples: Limited Liability Company Agreement (Clearway Energy LLC), Limited Liability Company Agreement (Clearway Energy, Inc.), Limited Liability Company Agreement (Clearway Energy, Inc.)
