LLC Agreement. For U.S. federal income Tax purposes, to the extent this Agreement imposes obligations upon the Company or a member of the Company, this Agreement shall be treated as part of the LLC Agreement as described in section 761(c) of the Code and sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 11 contracts
Samples: Tax Receivable Agreement (GEN Restaurant Group, Inc.), Tax Receivable Agreement (GEN Restaurant Group, Inc.), Tax Receivable Agreement (Rubicon Technologies, Inc.)
LLC Agreement. For U.S. federal income Tax purposes, to the extent this Agreement imposes obligations upon the Company or a member of the Company, this This Agreement shall be incorporated by reference and treated as part of the LLC Agreement as described in section Section 761(c) of the Code and sections Section 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations. Any payment under this Agreement is intended to constitute consideration received in a taxable sale pursuant to Section 1001 of the Code and shall, to the extent permitted by law, be so treated for U.S. income tax reporting purposes.
Appears in 2 contracts
Samples: Tax Receivable Agreement (CompoSecure, Inc.), Merger Agreement (Roman DBDR Tech Acquisition Corp.)
