Sprint Sub. LLC has been since its formation and each of the Transfer Entities will be, as of Closing, disregarded as an entity separate from its owner for U.S. federal income tax purposes pursuant to Treasury Regulation Section 301.7701-2(c)(2). No action has been taken by Sprint or any of its Affiliates to treat Sprint Sub LLC or any of the Transfer Entities other than as disregarded entities for U.S. federal income tax purposes as of and following the Closing.
Appears in 4 contracts
Samples: Transaction Agreement, Transaction Agreement (New Clearwire CORP), Transaction Agreement (Clearwire Corp)
