Partnership Continuation. The Members and the Company have agreed to treat the Company as a continuation of the Prior Partnership for U.S. federal (and applicable state and local) income tax purposes and to take no position inconsistent therewith except to the extent required by Law. In accordance with the foregoing, the Company shall use the U.S. employer identification number used by the Prior Partnership immediately prior to the Transactions.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Stronghold Digital Mining, Inc.), Limited Liability Company Agreement (Stronghold Digital Mining, Inc.), Limited Liability Company Agreement (Stronghold Digital Mining, Inc.)
Partnership Continuation. The Members and the Company have agreed to treat the Company as a continuation of the Prior Partnership for U.S. federal (and applicable state and local) income tax purposes and to take no position inconsistent therewith except to the extent required by Law. In accordance with the foregoing, the Company shall use the U.S. employer identification number used by the Prior Partnership immediately prior to the Transactionstransactions contemplated by that certain Master Transation Agreement, dated as of April 1, 2021, pursuant to which PubCo became admitted as a Member of the Company.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Stronghold Digital Mining, Inc.), Limited Liability Company Agreement (Stronghold Digital Mining, Inc.)
Partnership Continuation. The Upon completion of the Transactions, the Members and the Company have agreed to treat the Company as a continuation of the Prior Partnership for U.S. federal (and applicable state and local) income tax purposes and to take no position inconsistent therewith except to the extent required by Law. In accordance with the foregoing, the Company shall use the U.S. employer identification number used by the Prior Partnership immediately prior to the Transactions.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Stronghold Digital Mining, Inc.)
Partnership Continuation. The Upon completion of the Transactions, the Members and the Company have agreed agree to treat the Company as a continuation of the Prior Partnership for U.S. federal (and applicable state and local) income tax purposes and to take no position inconsistent therewith except to the extent required by Law. In accordance with the foregoing, the Company shall use the U.S. employer identification number used by the Prior Partnership immediately prior to the Transactions.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Stronghold Digital Mining, Inc.)
