Internal Revenue Service Elections. In the event that the Group is deemed to constitute a partnership for purposes of federal income taxes, you agree to elect to be excluded from the application of Subchapter K, Chapter 1, Subtitle A of the Internal Revenue Code, and you agree not to take any position inconsistent with such election. You authorize us, in our discretion as Manager, to execute on behalf of the Group such evidence of such election as may be required by the Internal Revenue Service.
Appears in 2 contracts
Samples: Master Agreement, Master Agreement
Internal Revenue Service Elections. In the event that the Group Account is deemed to constitute a partnership for purposes of federal income taxes, you agree to elect to be excluded from the application of Subchapter K, Chapter 1, Subtitle A of the Internal Revenue Code, and you agree not to take any position inconsistent with such election. You authorize us, in our discretion as Manager, to execute on behalf of the Group Underwriters such evidence of such election as may be required by the Internal Revenue Service.
Appears in 2 contracts
Samples: Master Agreement, Master Agreement
Internal Revenue Service Elections. In the event that tha t the Group Account is deemed to constitute a partnership for purposes of federal income taxes, you agree to elect to be excluded from the application of Subchapter K, Chapter 1, Subtitle A of the Internal Revenue Code, and you agree not to take any position inconsistent with such election. You authorize us, in our discretion as Manager, to execute on behalf of the Group Underwriters such evidence of such election as may be required by the Internal Revenue Service.
Appears in 1 contract
Samples: Purpose of Agreement
Internal Revenue Service Elections. In the event that the Group Account is deemed to constitute a partnership for purposes of federal income taxes, you agree to elect to be excluded from the application of Subchapter K, Chapter 1, Subtitle A of the Internal Revenue Code, and you agree not to take any position inconsistent with such election. You authorize us, in our discretion as Manager, to execute on behalf of the Group Members such evidence of such election as may be required by the Internal Revenue Service.
Appears in 1 contract
Samples: Joint Account Agreement