Tax Classification of the Company. It is intended that the Company be classified as a disregarded entity for purposes of United States federal income tax purposes.
Tax Classification of the Company. It is intended that the Company be classified as a partnership for United States federal income tax purposes.
Tax Classification of the Company. The Members intend and agree that as of the effective date of this Agreement the Company will be classified as a partnership for federal and state income tax purposes. The Members further agree to assist the Company in filing any and all elections required to ensure that the Company is classified as a partnership for federal and state income tax purposes.
Tax Classification of the Company. The Company is classified as a Subchapter C corporation for U.S. federal income tax purposes.
Tax Classification of the Company. The Company and the Sole Member acknowledge that for U.S. federal income tax purposes, the Company will be disregarded as an entity separate from the Sole Member pursuant to Treasury Regulations Section 301.7701-3 as long as all of the Membership Interests in the Company are owned by the Sole Member.
Tax Classification of the Company. The Member intends and agrees that the Company initially will be classified as a disregarded entity for federal and state income tax purposes.
Tax Classification of the Company. Unless otherwise determined by the Board, it is intended that the Company be classified as a partnership (other than a “publicly traded partnership”) for U.S. federal income tax purposes. Except with the approval of the Board, the Company shall not (a) file any election pursuant to Treasury Regulations Section 301.7701-3(c) to be treated as an entity other than a partnership or (b) elect, pursuant to Code Section 761(a), to be excluded from the provisions of subchapter K of the Code.
Tax Classification of the Company. (a) For U.S. federal income tax purposes, it is intended that (i) the Initial Conversion be treated as a complete liquidation of the Company under Section 332 of the Code; (ii) the Plan Distribution be treated as a distribution by NTI of undivided interest in the assets and liabilities of the Company followed by a contribution thereof to the Company and (iii) subject to Section 7.08(b), the Company be classified as a partnership for U.S. federal income tax purposes following the Plan Distribution, in accordance with Revenue Ruling 99-5, 1999-1 C.B. 434.
Tax Classification of the Company. Within seventy-five (75) days after the formation of the Company (and retroactive to the date of formation), Internal Revenue Service Form 8832 shall be filed electing for the Company to be classified as an association taxable as a corporation for United States federal income tax purposes. The Company and the Manager shall not, without the consent of the holders of a Units Majority, file any election pursuant to the Code or the Regulations to be treated as an entity other than a corporation.
Tax Classification of the Company. For federal income tax purposes, the Company is disregarded as an entity separate from its owner pursuant to Section 301.7701-3(b)(1)(ii) of the Treasury Regulations. Nevertheless, the Company is regarded for purposes of federal employment Taxes and related wage withholding beginning on the Conversion Date, and is also regarded for purposes of state Taxes (including Texas state margin Taxes).
