Tax Partnership. The Members acknowledge that, subject to Section 8.3 and the impact of an Internal Restructure, the Company shall be treated as a partnership for Federal income tax purposes and will not otherwise characterize the Company for purposes of any Federal tax returns, statements or reports filed by them or their Affiliates.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement
Tax Partnership. The Members acknowledge that, subject to Section 8.3 and the impact of an Internal Restructure, that the Company shall be treated as a partnership for Federal income tax purposes and will not otherwise characterize the Company for purposes of any Federal tax returns, statements or reports filed by them or their Affiliates.
Appears in 2 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Eagle Rock Energy Partners L P)
Tax Partnership. The Members acknowledge that, subject to Section 8.3 and the impact of an Internal Restructure, that the Company shall be treated as a partnership for Federal federal income tax purposes and will not elect to otherwise characterize the Company for purposes of any Federal tax returns, statements or reports filed by them or their Affiliatessuch purposes.
Appears in 1 contract
Tax Partnership. The Members acknowledge that, subject to Section 8.3 and the impact of an Internal Restructure, that the Company shall be treated as a partnership for Federal federal income tax purposes and will not elect to otherwise characterize the Company for purposes of any Federal tax returns, statements or reports filed by them or their Affiliatessuch purposes. Section 8.3.
Appears in 1 contract
Samples: Limited Liability Company Agreement (National Grid Transco PLC)
Tax Partnership. The Members acknowledge that, subject to Section 8.3 and the impact of an Internal Restructure, that the Company shall be treated classified as a partnership for Federal income tax purposes and will not otherwise characterize the Company for purposes of any Federal tax returns, statements or reports filed by them or their Affiliates, and this Agreement shall be interpreted accordingly.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Laredo Oil, Inc.)
Tax Partnership. The Members acknowledge that, subject to Section 8.3 and the impact of an Internal Restructure, that the Company shall be treated as a partnership for Federal federal income tax purposes and will not otherwise characterize the Company for purposes of any Federal federal tax returns, statements or reports filed by them or their Affiliates.
Appears in 1 contract
Samples: Limited Liability Company Agreement (AleAnna Energy, LLC)
