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.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Goal Capital Funding, LLC), Limited Liability Company Agreement (Goal Capital Funding, LLC), Limited Liability Company Agreement (Consolidation Loan Funding Ii, LLC)
Tax Treatment of the Company. It is intended that, so long as the Company has no more than one Member, to the extent the Company is treated as a partnership for U.S. federal income tax purposes, the Company shall be treated as a partnership that is not a publicly traded partnership. In the event that the Company shall have only one Member, it is intended that the Company 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.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Higher Education Funding I), Limited Liability Company Agreement (Consolidation Loan Funding, LLC)
