Section 754 Election. In its capacity as the sole managing member of the LLC, the Corporation will ensure that, on and after the date hereof and continuing throughout the term of this Agreement, the LLC and each of its direct and indirect Subsidiaries that is treated as a partnership for U.S. federal income tax purposes will have in effect an election under Section 754 of the Code (and under any similar provisions of applicable U.S. state or local law).
Appears in 10 contracts
Samples: Tax Receivable Agreement (Pluralsight, Inc.), Tax Receivable Agreement (I3 Verticals, Inc.), Tax Receivable Agreement (I3 Verticals, Inc.)
Section 754 Election. In its capacity as the sole managing member of the LLC, the The Corporation will shall ensure that, on and after the date hereof and continuing throughout the term of this Agreement, the LLC and each other member of its direct and indirect Subsidiaries the LLC Group that is treated as a partnership for U.S. federal income tax purposes will have in effect an election under Section 754 of the Code (and under any similar provisions of applicable U.S. state or local law).
Appears in 4 contracts
Samples: Tax Receivable Agreement (QualTek Services Inc.), Tax Receivable Agreement (Sky Harbour Group Corp), Tax Receivable Agreement (Roth CH Acquisition III Co)
Section 754 Election. In its capacity as the sole managing member of the LLC, the Corporation will ensure that, on and after the date hereof and continuing throughout the term of this Agreement, the LLC and each other member of its direct and indirect Subsidiaries the LLC Group that is treated as a partnership for U.S. federal income tax purposes will have in effect an election under Section 754 of the Code (and under any similar provisions of applicable U.S. state or local law).
Appears in 2 contracts
Samples: Tax Receivable Agreement (Shift4 Payments, Inc.), Tax Receivable Agreement (Shift4 Payments, Inc.)
