Tax Classifications Sample Clauses

Tax Classifications. The Company shall be classified as a partnership for U.S. federal income tax purposes. Each Member agrees that it shall not: (a) treat, on such Member’s individual income Tax Returns, any item of income, gain, loss, deduction or credit relating to such Member’s interest in the Company in a manner inconsistent with the treatment of such item by the Company as reflected on the Schedule K-1 or other information statement furnished by the Company to such Member for use in preparing its income Tax Return; provided, however, in the event a Member has in place, or otherwise adopts, xxxx-to-market accounting, such accounting methodology shall not be deemed to be inconsistent with the treatment of such item by the Company as reflected on the Schedule K-1 or other information statement furnished by the Company to such Members; or (b) file any claim for refund relating to any such item based on, or which would result in, such inconsistent treatment.
Sample 1Sample 2
AutoNDA by SimpleDocs
Tax Classifications. Xxxxxxxx Partners Coöperatief U.A., a cooperative organized under the laws of the Netherlands, has been treated as (i) an entity disregarded from its owner for U.S. federal income tax purposes and (ii) a corporation for Netherlands income tax purposes, both effective upon its formation on December 31, 2013. Xxxxxxxx Energy (Canada), Inc., (“WECI”), a corporation organized under the laws of New Brunswick, was treated as (i) a controlled foreign corporation for U.S. federal income tax purposes, (ii) a corporation for Canadian income tax purposes and (iii) a corporation for Netherlands income tax purposes, all effective upon formation on July 31, 2000 until November 6, 2012. On November 6, 2012, WECI converted to an Alberta unlimited liability corporation and changed its name to Xxxxxxxx Energy Canada ULC (“WECU”). From November 6, 2012 to date, WECU has been treated as (i) an entity disregarded from its owner for U.S. federal income tax purposes, (ii) a corporation for Canadian income tax purposes and (iii) a corporation for Netherlands income tax purposes. .
Sample 1
Tax Classifications. Schedule 2.6(f) identifies the federal income tax classifications of each of Kenton Ltd., PSI and Rentals.
Sample 1
Tax Classifications. Paragraph 16(k) (Tax Classifications) of Schedule 2 (Warranties) sets forth the entity classification of each Group Member for U.S. federal income tax purposes.
Sample 1

Related to Tax Classifications

  • Tax Classification The Series shall elect to be treated as an association taxable as a corporation under Treasury Regulations Section 301.7701-3 with effect for each taxable period of its existence. The Series and each Member shall file all tax returns and shall otherwise take all tax and financial reporting positions in a manner consistent with such treatment. No election will be filed with the Internal Revenue Service (or the tax authorities of any State) to have the Series taxable other than as an association taxable as a corporation for income tax purposes.

  • Classification 7.06 Employees who cannot support the Union because of a conscientious objection as determined by the Union’s internal guidelines may apply to the Union in writing.

  • Repair and classification Each Borrower shall keep the Ship owned by it in a good and safe condition and state of repair:

  • Industry Classification Groups For purposes of this Agreement, the Borrower shall assign each Portfolio Investment to an Industry Classification Group. To the extent that any Portfolio Investment is not correlated with the risks of other Portfolio Investments in an Industry Classification Group, such Portfolio Investment may be assigned by the Borrower to an Industry Classification Group that is more closely correlated to such Portfolio Investment. In the absence of any correlation, the Borrower shall be permitted, upon prior notice to the Administrative Agent and each Lender, to create up to three additional industry classification groups for purposes of this Agreement.

  • Allocations Generally The Company’s profit and loss shall be allocated to the Member.

  • Income Tax Allocations (a) Except as provided in this Section 4.3, each item of income, gain, loss and deduction of the Company for federal income tax purposes shall be allocated among the Members in the same manner as such items are allocated for Capital Account purposes under Section 4.1 and Section 4.2.

  • Income Tax Elections In the event of a distribution of property made in the manner provided under Section 734 of the Code, or in the event of a transfer of any Partnership Interest permitted by this Agreement made in the manner provided in Section 743 of the Code, the General Partner, on behalf of the Partnership, may, but shall not be required to, file an election under Section 754 of the Code in accordance with the procedures set forth in the applicable regulations promulgated thereunder.

  • Tax Claims Notwithstanding any other provision of this Agreement, the control of any claim, assertion, event or proceeding in respect of Taxes of the Company (including, but not limited to, any such claim in respect of a breach of the representations and warranties in Section 3.22 hereof or any breach or violation of or failure to fully perform any covenant, agreement, undertaking or obligation in Article VI) shall be governed exclusively by Article VI hereof.

  • Allocation of Tax Items To the extent permitted by section 1.704-1(b)(4)(i) of the Treasury Regulations, all items of income, gain, loss and deduction for federal and state income tax purposes shall be allocated to the Members in accordance with the corresponding "book" items thereof; however, all items of income, gain, loss and deduction with respect to Assets with respect to which there is a difference between "book" value and adjusted tax basis shall be allocated in accordance with the principles of section 704(c) of the IRS Code and section 1.704-1(b)(4)(i) of the Treasury Regulations, if applicable. Where a disparity exists between the book value of an Asset and its adjusted tax basis, then solely for tax purposes (and not for purposes of computing Capital Accounts), income, gain, loss, deduction and credit with respect to such Asset shall be allocated among the Members to take such difference into account in accordance with section 704(c)(i)(A) of the IRS Code and Treasury Regulation section 1.704-1(b)(4)(i). The allocations eliminating such disparities shall be made using any reasonable method permitted by the Code, as determined by the Manager.

Draft better contracts in just 5 minutes Get the weekly Law Insider newsletter packed with expert videos, webinars, ebooks, and more!