Tax Treatment of the Company. It is the intent of the Members that the Company be treated as a partnership for U.S. federal income tax purposes. Neither the Company nor any Member shall make an election to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as an association pursuant to Treasury Regulation Section 301.7701-3.
Tax Treatment of the Company. It is intended that, so long as the Company has no more than one Member, the Company shall be treated as an entity the existence of which is disregarded as separate from such Member for U.S. federal income tax purposes. In the event the Company has more than one Member, it is intended that the Company shall be treated as a partnership that is not a publicly traded partnership for U.S. federal income tax purposes. Notwithstanding any other provision of this Agreement, neither the Company nor any Member shall take any action inconsistent with such intentions.
Tax Treatment of the Company. The Company shall be treated as a partnership for U.S. federal, state, local and non-U.S. tax purposes, to the extent applicable. The Manager and the Members shall take no action (or fail to take any action) that could cause the Company to be treated as other than in accordance with the first sentence of this Section 13.4.
Tax Treatment of the Company. The Buyer will not take any action (including the filing of an IRS Form 8832 on which the Buyer elects to have the Company treated as a corporation) that could cause the Company to be characterized for federal or state income tax purposes as a corporation during any period (or portion thereof) ending on or prior to the Closing Date.
Tax Treatment of the Company. It is intended that the Company be disregarded as an entity separate from its owner for federal tax purposes. For this reason, the Company shall not elect to be classified as a corporation on Form 8832, "Entity Classification Election", but, instead, will be treated by default as an entity disregarded as separate from its owner pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii). Furthermore, it is intended that the Company be disregarded as an entity separate from its owner for state tax purposes, and the Company shall take such actions as are necessary to cause this result.
Tax Treatment of the Company. The Member and the Company intend that, for so long as the Company has a single Member, the Company shall be treated as disregarded as an entity separate from the Member for U.S. federal tax purposes pursuant to Treas. Reg. Section 301.7701-3 (and for all applicable U.S. state and local tax purposes under analogous provisions of U.S. state and local tax law). No election shall be made under Treas. Reg. Section 301.7701-3 (or under any applicable analogous provisions of U.S., state or local tax law) to treat the Company as an association taxable as a corporation for U.S. federal tax purposes (or for applicable U.S., state or local tax purposes).
Tax Treatment of the Company. It is the intention of the Member that the Company not be treated as an association or a corporation for tax purposes but instead, pursuant to Treasury Regulations section 301.7701—3, be disregarded as separate from the Member for federal, state, and local tax purposes. Neither the Company nor the Member shall file (or permit to be filed) an election under Treasury Regulations section 301.7701-3 (or any corresponding or similar provision of state or local law) to cause the Company to be classified as an association or corporation for tax purposes.
Tax Treatment of the Company. The Members acknowledge that the Company shall be treated as a partnership for U.S. federal income tax purposes and all applicable state tax purposes.
Tax Treatment of the Company. The amount of income recognized by Xx. Xxxxxxxx hereunder in accordance with the foregoing discussion may be an expense deductible by the Company for federal income tax purposes of the taxable year of the Company during which the recipient recognizes income.
Tax Treatment of the Company. The Company shall (i) be operated in a manner consistent with treatment as a “partnership” for federal and (if applicable) state and local income tax purposes, and (ii) not be operated or treated as a “partnership” for purposes of Section 303 of the Federal Bankruptcy Code. The Member agrees (i) to treat the Company in the same manner for applicable income tax purposes, and (ii) not to take any action inconsistent with the Company’s tax treatment as established by operation of this Section 2(c).
