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 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 Company is classified as a Subchapter C corporation for U.S. 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 and the Members intend that, for U.S. federal and applicable state income tax purposes, the Company shall be treated as a partnership. Unless otherwise approved by the Members, neither the Company nor any Member shall make an election for the Company to be classified as other than a partnership for U.S. federal and applicable state income tax purposes.
Tax Classification of the Company. The Members intend and agree that the Company will be classified for federal tax purposes as a “disregarded entity” within the meaning of Section 301.7701-3 of the United States Treasury Regulations.
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. 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).
Tax Classification of the Company. It is intended that the Company be classified as a partnership for U.S. federal income tax purposes. The Company shall file an election pursuant to Section 301.7701-3(c) of the United States Treasury Regulations to be treated as a partnership and shall not file any election thereunder to be treated as an entity other than a partnership. The Company shall not take any action inconsistent with such election.
