Partnership Tax Treatment. The Members intend for the Company to be treated as a partnership for federal income tax purposes and no election to the contrary shall be made.
Partnership Tax Treatment. It is the intention of the Members that the Company be treated as a partnership for Federal, state and local income tax purposes, and the Interest Holders shall not take any position or make any election, in a tax return or otherwise, inconsistent with such treatment.
Partnership Tax Treatment. The Partners intend for the Partnership to be treated as a partnership for United States federal income tax purposes and no election to the contrary shall be made. In the event any Private Vehicle is registered under the 1940 Act, the Partnership shall not make an election pursuant to Section 1278(b) of the Code.
Partnership Tax Treatment. The Partners intend for the Partnership to be treated as a partnership for U.S. federal income tax purposes and no election to the contrary shall be made unless the General Partner in its sole discretion determines that other treatment or election is in the best interests of the Partnership.
Partnership Tax Treatment. The Members intend that the Company be treated as a partnership for federal, state and local income tax purposes and the Company and each Member shall file all tax returns on the basis consistent therewith. Specifically, the Members intend that the Company shall not be a partnership (including, without limitation, a limited partnership) or joint venture and that no Interest Holder shall be a partner or joint venturer of any other Interest Holder for any purposes other than federal, state and local tax purposes, and this Agreement shall not be construed to suggest otherwise.
Partnership Tax Treatment. Each Member acknowledges that it understands and intends that the arrangement created hereunder is a partnership for federal (and applicable state and local) income tax purposes and that it intends and expects to be treated as a partner thereof for such purposes. The Members agree that, unless otherwise required by appropriate tax authorities, neither the Company nor any Member shall file or cause to be filed annual returns, reports or other forms inconsistent with such stated intent. No election to treat the Company other than as a partnership for federal income tax purposes or any relevant state or local tax purposes shall be made by or on behalf of the Company or any Member.
Partnership Tax Treatment. The Members expect and intend that the LLC shall be treated as a partnership for all federal income tax purposes, and the Members agree that they will not: (a) take a position on any federal, state, local or other tax return or otherwise assert a position, inconsistent with such expectation and intent; or (b) do any act or thing which could cause the LLC to be treated as other than a partnership for federal income tax purposes.
Partnership Tax Treatment. Notwithstanding anything to the contrary in this Agreement, no Manager shall have the authority to cause the Company to be taxed as a corporation, rather than a partnership, in accordance with the “check-the-box” rules under Treasury Regulations Section 301.7701-3.
Partnership Tax Treatment. Borrower shall take all action to ------------------------- obtain and maintain its partnership treatment for federal and state purposes in accordance with all Governmental Requirements.
Partnership Tax Treatment. Each of the Company and any other Subsidiary that is a partnership or a limited liability company has been properly classified either as a partnership or as an entity disregarded as separate from ARC for Federal income tax purposes throughout the period from its formation through the date hereof.
