Tax Classification; No State Law Partnership. The Members intend that the Company shall be treated as a partnership for federal, state and local tax purposes. Each Member and the Company agree to file all tax returns and otherwise take all tax and financial reporting positions in a manner consistent with such treatment. No provision of this Agreement shall be deemed or construed to constitute the Company (including its Subsidiaries) as a partnership (including a limited partnership) or joint venture, or any Member as a partner of or with any other Member for any purposes other than tax purposes.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Keane Group, Inc.), Limited Liability Company Agreement (Keane Group, Inc.), Limited Liability Company Agreement (Albertsons Companies, Inc.)
Tax Classification; No State Law Partnership. The Members intend that the Company shall be treated as a partnership for federal, state and local tax purposes. Each Member and the Company agree to file all tax returns and otherwise take all tax and financial reporting positions in a manner consistent with such treatment. No provision of this Agreement shall be deemed or construed to constitute the Company (including its Subsidiariessubsidiaries) as a partnership (including a limited partnership) or joint venture, or any Member as a partner of or with any other Member for any purposes other than tax purposes.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Safeway Stores 42, Inc.), Operating Agreement (FUND.COM Inc.)
Tax Classification; No State Law Partnership. The Members intend that the Company shall is intended to be treated classified as a partnership for federal, U.S. federal (and applicable state and local local) income tax purposes. Each Member Other than for U.S. federal (and applicable state and local) income tax purposes, the Company agree to file all tax returns shall not be a partnership or joint venture for any other purpose, and otherwise take all tax and financial reporting positions in a manner consistent with such treatment. No provision no Member shall, by virtue of this Agreement shall Agreement, be deemed a partner or construed to constitute joint venturer of any other Member. Neither the Company (including its Subsidiaries) as a partnership (including a limited partnership) or joint venture, or any Member as a partner nor the Managers shall change the classification of or with any other Member the Company for any U.S. federal income tax purposes other than tax purposeswithout the unanimous prior written consent of the Members.
Appears in 1 contract
Samples: Limited Liability Company Agreement (CQENS Technologies Inc.)