Related Person. Such Transfer will not result in either (1) a Member being a “related person” with respect to any lender under the Financing Documents for purposes of Treasury Regulation Section 1.752-4(b), or (2) the Company being a “related person” to any purchaser under any power purchase agreement for power delivered from a Facility for purposes of Sections 267 or 707 of the Code.
Appears in 7 contracts
Samples: Operating Agreement (Bloom Energy Corp), Operating Agreement (Bloom Energy Corp), Equity Capital Contribution Agreement (Bloom Energy Corp)