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 Members expect and intend that the Company shall be treated as a partnership for all federal and state 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) elect for the Company to be treated as an association for tax purposes or do any other act or thing which could cause the Company to be treated as other than a partnership for federal income tax purposes.
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. 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. Subject to Section 5.09, the Partners intend for the Partnership to be treated (x) as a partnership and (y) a QOF until after the OZ Period for U.S. federal income tax purposes.
Partnership Tax Treatment. It is intended that the Partnership will be treated as a disregarded entity for U.S. federal income tax purposes, and no election will be made to the contrary without the consent of the Limited Partner.
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. 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.
