Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal income tax purposes.
Appears in 18 contracts
Samples: Agreement and Plan of Reorganization (SeqLL, Inc.), Limited Liability Company Agreement (Frontier Communications Corp), Operating Agreement
Taxation as Partnership. The Members intend that the Company shall be treated as a partnership for U.S. federal United States Federal 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 income tax purposes.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Cinergy Corp), Limited Liability Company Agreement (Cinergy Corp), Limited Liability Company Agreement (Cinergy Corp)
Taxation as Partnership. The Company shall be treated as a ----------------------- partnership for U.S. federal income tax purposes.
Appears in 4 contracts
Samples: Operating Agreement (Bioral Nutrient Delivery LLC), Limited Liability Company Operating Agreement (Bioral Nutrient Delivery LLC), Operating Agreement (Biodelivery Sciences International Inc)
Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal income United States federal, state, local and foreign tax purposespurposes and will make any necessary elections to achieve such status.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Usa Networks Inc), Limited Liability Company Agreement (Norfolk Southern Corp), Limited Liability Company Agreement (Tele Communications Inc /Co/)
Taxation as Partnership. The Company shall will elect to be treated as a partnership for U.S. United States federal income tax purposes.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (BGLS Inc), Limited Liability Company Agreement (BGLS Inc)
Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal income tax purposes.
Appears in 2 contracts
Samples: Operating Agreement (Advanced Na, LLC), Operating Agreement (Radiation Therapy Services Holdings, Inc.)
Taxation as Partnership. The Members agree that the Company shall will seek to be treated as a partnership for U.S. United States federal income tax purposes.
Appears in 2 contracts
Samples: Operating Agreement, Operating Agreement
Taxation as Partnership. The Company shall be treated as a partnership for U.S. United States federal income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Coca-Cola Consolidated, Inc.)
Taxation as Partnership. The Members intend that the Company shall will be treated as a partnership for U.S. federal income tax purposes and, to the extent permitted under applicable law, all other income tax purposes.
Appears in 1 contract
Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal Federal income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Simon Arnold H)
Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal income tax purposes. The Members agree to take all reasonable actions, including the amendment of this Agreement and the execution of such other documents, agreements and instruments as may reasonably be required in order for the Company to qualify for and receive "partnership" treatment for federal, state and local income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Northstar Capital Investment Corp /Md/)
Taxation as Partnership. The Members recognize that the Company shall will be treated as a partnership for U.S. federal income tax purposes, and the Board of Managers shall operate the Company in such a manner as will preserve its treatment as a partnership for U.S. federal income tax purposes.
Appears in 1 contract
Taxation as Partnership. The Company shall Partnership will be treated as a partnership for U.S. federal income tax purposespurposes and will be an accrual basis taxpayer.
Appears in 1 contract
Samples: Limited Liability Limited Partnership Agreement (GCM Grosvenor Inc.)
Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal income United States federal, state, local and foreign tax purposes.purposes and will make any necessary elections to achieve such status. ARTICLE XI
Appears in 1 contract
Taxation as Partnership. The Company shall be treated as a partnership for U.S. federal and state income and franchise tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Times Mirror Co /New/)
