Taxation as a Partnership. The Company shall take any necessary steps to be treated as a partnership for U.S. federal income tax purposes and shall not file any election to be treated as anything other than a partnership for such purposes.
Appears in 15 contracts
Samples: Administration Agreement (Teco Energy Inc), Administration Agreement (UBS Preferred Funding Trust VIII), Limited Liability Company Agreement (UBS Preferred Funding Trust VIII)
Taxation as a Partnership. The Company shall take any necessary steps to be treated as a partnership for U.S. U. S. federal income tax purposes and shall not file any election to be treated as anything other than a partnership for such purposes. The Bank and the Company will use their commercially reasonable efforts to ensure that the Company will not be an association or a publicly traded partnership taxable as a corporation for United States federal income tax purposes.
Appears in 7 contracts
Samples: Limited Liability Company Agreement (Deutsche Bank Contingent Capital LLC V), Limited Liability Company Agreement (Deutsche Bank Contingent Capital LLC II), Limited Liability Company Agreement (Deutsche Bank Contingent Capital LLC III)
Taxation as a Partnership. The Company shall take any necessary steps to and all Members intend that the Company be treated as a partnership for U.S. federal income tax purposes purposes. The Company and any Member shall take any action necessary to achieve this treatment and shall not file any election to be treated take no action inconsistent therewith. The Manager is hereby designated as anything other than a partnership for such purposesthe Tax Matters Representative.
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement, Limited Liability Company Agreement
Taxation as a Partnership. The Company LLC shall take any necessary steps to be treated as a partnership for U.S. federal income tax purposes and shall not file any election to be treated as anything other than a partnership for such purposes.
Appears in 1 contract
Taxation as a Partnership. The Company shall take any necessary steps to be treated as a partnership for U.S. U. S. federal income tax purposes and shall not file any election to be treated as anything other than a partnership for such purposes. The 42 Bank and the Company will use their commercially reasonable efforts to ensure that the Company will not be an association or a publicly traded partnership taxable as a corporation for United States federal income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Deutsche Bank Capital Funding Trust XII)
