Tax Classification. The Company shall be treated as a “disregarded entity” (within the meaning of Treasury Regulation § 301.7701-3) for U.S. federal income tax purposes. The Company (i) will not elect to be treated as an association taxable as a corporation, (ii) will, to the extent necessary, timely take such actions to ensure that it is treated as a disregarded entity, and (iii) will elect corresponding treatment for all state and local tax purposes.
Appears in 16 contracts
Samples: Limited Liability Company Agreement (CBL/Regency I, LLC), Limited Liability Company Agreement (CBL/Regency I, LLC), Limited Liability Company Agreement (CBL/Regency I, LLC)
Tax Classification. The Member intends that the Company shall be treated as a “"disregarded entity” (" within the meaning of Treasury Regulation § Regulations Section 301.7701-32(c)(2) for U.S. federal and applicable state income tax purposes. The Company (i) purposes and will not elect to be treated as an association taxable as a corporation, (ii) will, to the extent necessary, timely take file its tax returns consistent with such actions to ensure that it is treated as a disregarded entity, and (iii) will elect corresponding treatment for all state and local tax purposestreatment.
Appears in 2 contracts
Samples: Operating Agreement, Operating Agreement