Tax Classification. The Member intends that the Company be disregarded as an entity separate from the Member for Federal tax purposes effective as of the date of this Agreement. The Member shall not file any election for the Company to be taxable as an association for Federal tax purposes.
Appears in 26 contracts
Samples: Limited Liability Company Operating Agreement (Wendy's Restaurants, LLC), Limited Liability Company Operating Agreement (Wendy's of Denver, Inc.), Limited Liability Company Operating Agreement (Wendy's of Denver, Inc.)
Tax Classification. The Member intends that the Company be disregarded as an entity separate from the Member for Federal tax purposes effective as of the date of this Agreement. The Member shall not file any election for the Company to be taxable as an association for Federal tax purposes.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Williams Scotsman Inc), Limited Liability Company Agreement (Grand Canal Shops Mall Construction LLC), Limited Liability Company Agreement (Grand Canal Shops Mall Construction LLC)
Tax Classification. The Member recognizes and intends that the Company will be disregarded as an entity separate from the Member its owner for Federal income tax purposes effective as of the date of this Agreement. The Member shall purposes, and will not file any make an election for the Company to be taxable treated as an association taxable as a corporation for Federal U.S. federal income tax purposespurposes pursuant to Treasury Regulation Section 301.7701-3, or any successor provision thereof, and to the extent necessary, the Company and the Member will make any election required to obtain treatment consistent with the foregoing.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Covanta Energy Corp), Limited Liability Company Agreement (Covanta Energy Corp), Limited Liability Company Agreement (Covanta Energy Corp)
Tax Classification. The Member intends Members intend that the Company be disregarded as an entity separate from the Ordinary Member for U.S. Federal tax purposes effective as of the date of this Agreement. The No Member shall not file any election for the Company to be taxable as an association for Federal tax purposes, or take any position for U.S. Federal tax purposes inconsistent with this Section 15 (unless otherwise required by a change in applicable law or a final determination in appropriate proceedings).
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Wendy's of Denver, Inc.)
Tax Classification. The Member intends that the Company be disregarded as an entity separate from the Member for Federal tax purposes effective as of the date of this Agreement. The Member shall not file any election for the Company to be taxable as an association for Federal tax Tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Venetian Casino Resort LLC)
