Tax Reporting and Characterization. (a) To the fullest extent permitted by law, the Member and the Holder of each Series agree that solely for U.S. federal, state and local income and franchise tax purposes it will either treat its interest in the related Series Interest as a direct ownership interest in the related Series Assets or treat the applicable Series as a separate entity under the principles of Treas. Reg. § 301.7701-3 and Treas. Reg. § 301.7701-4 (that is also a separate from any other Series). Under the latter treatment, if an applicable Series has more than one owner for U.S. federal income tax purposes, the Series shall be intended to qualify as a partnership for such tax purposes that has elected out of partnership status under section 761 of the Code (and analogous state tax law).
Appears in 4 contracts
Samples: Titling Company Agreement (Nissan Auto Leasing LLC Ii), Limited Liability Company Agreement (Nissan Auto Leasing LLC Ii), Limited Liability Company Agreement (Nissan Auto Leasing LLC Ii)
