TAX CHARACTERIZATION AND ADDITIONAL TAX TERMS. For federal income tax purposes, and to the extent applicable for state and local income and franchise tax purposes, it is intended that the Company be disregarded as an entity separate from the Member; provided, however, if it is determined that there are two or more members of the Company then it is intended that the Company be treated as a partnership for such purposes, and the Managing Member shall (i) file any information returns and reports and make any elections or take any other similar action required for the Company to be classified as a partnership for such purposes and (ii) act as the tax matters partner of the Company pursuant to Section 6231(a)(7) of the Code and applicable Tax Regulations.
Appears in 9 contracts
Samples: Limited Liability Company Operating Agreement (Dvi Receivables Corp Viii), Limited Liability Company Operating Agreement (Dvi Receivables Corp Viii), Limited Liability Company Operating Agreement (Dvi Receivables Corp Viii)
