Section 754 Election. The Company has previously made or will make a timely election under Section 754 of the Code (and a corresponding election under state and local law) effective starting with the taxable year ended December 31, 2020, and the Managing Member shall not take any action to revoke such election.
Appears in 9 contracts
Samples: Operating Agreement (Rocket Companies, Inc.), Operating Agreement (Clear Secure, Inc.), Operating Agreement (Clear Secure, Inc.)
Section 754 Election. The Company has previously made or will make a timely election under Section 754 of the Code (and a corresponding election under state and local law) effective starting with the taxable year ended December 31, 20202011, and the Managing Member shall not take any action to revoke such election.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Virtu Financial, Inc.), Limited Liability Company Agreement (Virtu Financial, Inc.), Limited Liability Company Agreement (Virtu Financial, Inc.)
Section 754 Election. The Company has previously made or will make a timely election under Section 754 of the Code (and a corresponding election under state and local law) effective starting with the taxable year ended December 31, 2020in the year in which the Effective Date occurs, and the Managing Member Manager shall not take any action to revoke such election.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Alvarium Tiedemann Holdings, Inc.), Limited Liability Company Agreement (Figdor Drew), Limited Liability Company Agreement (Tiedemann Michael)
Section 754 Election. The Company has previously made or will shall make a timely election under Section 754 of the Code (and a corresponding election under state and local law) effective starting with the taxable year ended December 31, 20202015, and the Managing Member shall not take any action to revoke such election.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (vTv Therapeutics Inc.), Limited Liability Company Agreement (vTv Therapeutics Inc.)
Section 754 Election. The Company has previously made or will make a timely election under Section 754 of the Code (and a corresponding election under state and local law) effective starting with the taxable year ended December 31, 2020, and the Managing Member Manager shall not take any action to revoke such election.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (UWM Holdings Corp), Limited Liability Company Agreement (UWM Holdings Corp)
Section 754 Election. The Company has previously made or will agrees to make a valid, timely and effective election under Section 754 of the Code (and a corresponding election under state and local law) effective starting with the for its short taxable year ended December 31, 2020, ending on the Closing Date and the Managing Member shall Sellers agree not to take any action to revoke cause such electionelection to be revoked for any subsequent taxable period.
Appears in 1 contract
Samples: Unit and Stock Purchase Agreement (Ducommun Inc /De/)
Section 754 Election. The Company has previously made or will make a timely election under Section 754 of the Code (and a corresponding election under state and local law) effective starting with the taxable year ended December 31, 2020in the year in which the Effective Date (as defined in the Second Amended and Restated Agreement) occurs, and the Managing Member Manager shall not take any action to revoke such election.
Appears in 1 contract
Samples: Limited Liability Company Agreement (AlTi Global, Inc.)
