Partnership Status. The Members intend to treat the Company as a partnership for U.S. federal income tax purposes and notwithstanding anything to the contrary herein, no election to the contrary shall be made.
Appears in 11 contracts
Samples: Limited Liability Company Agreement (Calyxt, Inc.), Limited Liability Company Agreement (Highland Transcend Partners I Corp.), Operating Agreement (Wm Technology, Inc.)
Partnership Status. The Members intend to treat the Company as a partnership for U.S. federal income tax purposes and notwithstanding anything to the contrary herein, no election to the contrary shall be mademade without the consent of each of the Members.
Appears in 3 contracts
Samples: Business Combination Agreement (Spree Acquisition Corp. 1 LTD), Limited Liability Company Agreement (OPAL Fuels Inc.), Business Combination Agreement (ArcLight Clean Transition Corp. II)
Partnership Status. The Members intend to treat for the Company to be treated as a partnership for U.S. federal income tax purposes and notwithstanding anything to the contrary herein, no election to the contrary shall be made.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Exeter Finance Corp)