Partnership Status of Company. The Company intends to be treated as a partnership for U.S. federal income tax purposes. Notwithstanding anything herein to the contrary, the Company shall not make an election (i.e., check-the-box) under Treasury Regulation Section 301.7701-3 for the Company to be classified for federal income tax purposes as an association taxable as a corporation.
Appears in 9 contracts
Samples: Limited Liability Company Agreement (Goldman Sachs Private Markets Fund 2018 LLC), Limited Liability Company Agreement (Goldman Sachs Private Markets Fund 2018 (A) LLC), Limited Liability Company Agreement (Goldman Sachs Private Markets Fund 2018 (B) LLC)
Partnership Status of Company. The Managing Member intends for the Company intends to be treated as a partnership for U.S. federal income tax purposes. Notwithstanding anything herein to the contrary, neither the Company nor the Managing Member shall not make an election (i.e., check-the-box) under Treasury Regulation Section 301.7701-3 for the Company to be classified for federal income tax purposes as an association taxable as a corporation.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Goldman Sachs Hedge Fund Partners Ii LLC), Limited Liability Company Agreement (Goldman Sachs Hedge Fund Partners Ii LLC), Limited Liability Company Agreement (Goldman Sachs Hedge Fund Partners Ii LLC)
Partnership Status of Company. The Managing Member intends for the Company intends to be treated as a partnership for U.S. federal income tax purposes. Notwithstanding anything herein to the contrary, neither the Company nor the Managing Member shall not make an election (i.e., check-the-box) under Treasury Regulation Regulations Section 301.7701-3 for the Company to be classified for federal income tax purposes as an association taxable as a corporation.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Goldman Sachs Hedge Fund Partners LLC), Limited Liability Company Agreement (Goldman Sachs Hedge Fund Partners Ii LLC)
