Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal income tax purposes.
Taxation as Partnership. The Members intend and agree that the Company will be treated as a partnership for United States federal, state and local income tax purposes. Each Member and the Company agrees that it will not cause or permit the Company to: (i) be excluded from the provisions of Subchapter K of the Code, under Code Section 761, or otherwise, (ii) file the election under Regulations Section 301.7701-3 (or any successor provision) which would result in the Company being treated as an entity taxable as a corporation for federal, state or local tax purposes or (iii) do anything that would result in the Company not being treated as a “partnership” for United States federal and, as applicable, foreign, state and local income tax purposes. Each Member and the Company shall file all tax returns and shall otherwise take all tax and financial reporting positions in a manner consistent with such treatment.
Taxation as Partnership. To the extent permitted by applicable law, the Company intends to be treated as a partnership for United States federal, state and local tax purposes and the Members and the Company will make any necessary elections to achieve this result and refrain from making any elections that would have a contrary result. No Member shall knowingly take any action that is inconsistent with the classification of the Company as a partnership for United States federal, state and local tax purposes.
Taxation as Partnership. The Company shall be treated as a partnership for tax purposes. The Company shall avail itself of any election or procedure under the Code or the Regulations and under state and local tax law, including any "check-the-box" election, for purposes of having an entity classified as a partnership for tax purposes, and the Members shall cooperate with the Company in connection therewith and hereby authorize the Manager, directors, and officers to take whatever actions and execute whatever documents are necessary or appropriate to effectuate the foregoing.
Taxation as Partnership. The Manager and the Members shall take all actions and make such elections as may be required to cause the Company to be treated as a partnership for income tax purposes. Neither the Company nor any Member may make an election for the Company to be taxable as a corporation for federal income tax purposes or to be excluded from the application of the provisions of subchapter K of chapter I of subtitle A of the Code or any similar provisions of applicable state law, and no provision of this Agreement shall be construed to sanction or approve such an election.
Taxation as Partnership. The Company shall be treated as a partnership for United States federal and state income tax purposes and the Members agree not to take any action inconsistent with the Company's classification as a partnership for United States federal and State income tax purposes. By executing this Agreement, each of the Members hereby consents to, and the TMM shall, take any action necessary, including, without limitation, the execution of any forms and documents, for the Company to be treated as a partnership for United States federal and state income tax purposes.
Taxation as Partnership. 21 SECTION 10.......................................................................................................22 BANKING; ACCOUNTING; BOOKS AND RECORDS...........................................................................22
Taxation as Partnership. The Members recognize that the Company will be treated as a partnership for U.S. federal income tax purposes. The Manager shall operate the Company in such a manner and shall take all necessary action as will establish and preserve the Company's treatment as a partnership for U.S. federal income tax purposes. The Company shall not make any election to be treated as other than a partnership for U.S. federal income tax purposes.
Taxation as Partnership. The Company shall be treated as a "partnership" for Federal and state income tax purposes. All provisions of this Agreement and the Articles shall be construed and applied so as to preserve that tax status. 8.5
Taxation as Partnership. The General Partners, while serving as such, agree to use their best efforts to cause compliance at all times with the conditions to the continued effectiveness of any opinion of counsel obtained by the Partnership to the effect that the Partnership will be classified as a partnership for federal income tax purposes.
