Tax Receivables Agreement. The Tax Receivables Agreement shall be treated as part of this Agreement as described in Section 761(c) of the Code, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations with respect to payments to a Member with respect to an Exchange (as defined in the Tax Receivables Agreement) by such Member.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (MediaAlpha, Inc.), Limited Liability Company Agreement (MediaAlpha, Inc.), Operating Agreement (Evolent Health, Inc.)
Tax Receivables Agreement. The Tax Receivables Agreement shall be treated as part of this Agreement as described in Section 761(c) of the Code, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations with respect to payments to a Member with respect to an Exchange (as defined in the Tax Receivables Agreement) by such Member.. [Signature pages follow]
Appears in 1 contract
Tax Receivables Agreement. The Tax Receivables Agreement shall be treated as part of this Operating Agreement as described in Section 761(c) of the Code, and Sections Treas. Reg. § 1.704-1(b)(2)(ii)(h) and § 1.761-1(c) of the Treasury Regulations with respect to payments to a Member with respect to an Exchange (as defined in the Tax Receivables Agreement) by such Member.
Appears in 1 contract
Samples: Operating Agreement (OTG EXP, Inc.)
