Tax Reporting and Characterization. It is the Mem-ber's express intention that for purposes of federal, state and local income tax laws the Company be treated as an entity disregarded as separate from the Member (a "DRE") so long as there is only one Member for U.S. federal income tax purposes and for any period when there are two or more Members to be treated as a partnership, and the Tax Matters Partner is expressly authorized to make any election it deems necessary or appropriate to effect or maintain such treatment.
Appears in 2 contracts
Samples: Operating Agreement (Claymore MACROshares Oil Down Holding Trust), Operating Agreement (Claymore MACROshares Oil Up Holding Trust)
Tax Reporting and Characterization. It is the Mem-ber's Member’s express intention that for purposes of federal, state and local income tax laws the Company be treated as an entity disregarded as separate from the Member (a "DRE") so long as there is only one Member for U.S. federal income tax purposes and for any period when there are two or more Members to it is the Members’ express intention that the Company be treated as a partnership, and the Tax Matters Partner is expressly authorized to make any election it deems necessary or appropriate to effect or maintain such treatment.
Appears in 1 contract
Samples: Operating Agreement (MacroShares Housing Depositor, LLC)
Tax Reporting and Characterization. It is the Mem-ber's Members' express intention that for purposes of federal, state and local income tax laws the Company be treated as an entity disregarded as separate from the Member (a "DRE") so long as there is only one Member for U.S. federal income tax purposes and for any period when there are two or more Members to be treated as a partnership, and the Tax Matters Partner is expressly authorized to make any election it deems necessary or appropriate to effect or maintain such treatment.
Appears in 1 contract
Samples: Operating Agreement (Macro Inflation Depositor, LLC)
Tax Reporting and Characterization. It is the Mem-ber's Members' express intention that for purposes of federal, state and local income tax laws the Company be treated as an entity disregarded as separate from the Member (a "DRE") so long as there is only one Member for U.S. federal income tax purposes and for any period when there are two or more Members to be treated as a partnership, and the Tax Matters Partner is expressly authorized to make any election it deems necessary or appropriate to effect or maintain such treatment.
Appears in 1 contract
Samples: Operating Agreement (MacroShares $100 Oil Down Trust)
Tax Reporting and Characterization. It is the Mem-berMember's express intention that for purposes of federal, state and local income tax laws the Company be treated as an entity disregarded as separate from the Member (a "DRE") so long as there is only one Member for U.S. federal income tax purposes purposes, and for any period when there are two or more Members to it is the Members' express intention that the Company be treated as a partnership, and the Tax Matters Partner is expressly authorized to make any election it deems necessary or appropriate to effect or maintain such treatment.
Appears in 1 contract
Samples: Operating Agreement (MacroShares $100 Oil Up Trust)