Taxation as Partnership. The Members intend that the Company shall be treated as a partnership for 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 3 contracts
Samples: Limited Liability Company Agreement (Cinergy Corp), Limited Liability Company Agreement (Cinergy Corp), Limited Liability Company Agreement (Cinergy Corp)
Taxation as Partnership. The Members intend that the Company shall be treated as a partnership for 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 U.S. federal income tax purposes. The Members intend that the Company not be operated or treated as a “partnership” for purposes of Section 303 of the Federal Bankruptcy Code.
Appears in 2 contracts
Samples: Co Venture Agreement (VirTra, Inc), Co Venture Agreement (Nuvola, Inc.)
Taxation as Partnership. The Members intend recognize that the Company shall will be treated as a partnership for United States Federal U.S. federal income tax purposes purposes. The Manager shall operate the Company in such a manner and the Members agree not to shall take any all necessary action inconsistent with as will establish and preserve the Company's classification treatment as a partnership for United States Federal 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.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Cellnet Data Systems Inc), Limited Liability Company Agreement (Cellnet Data Systems Inc)
Taxation as Partnership. The Members intend recognize that the Company shall will be treated as a partnership for United States Federal U.S. federal income tax purposes purposes, and the Members agree not to Manager shall operate the Company in such a manner and will take any all necessary action inconsistent with the Company's classification as will preserve its treatment as a partnership for United States Federal U.S. federal income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Icg Funding LLC)
Taxation as Partnership. The Members intend recognize that the Company shall will be treated as a partnership for United States Federal U.S. federal income tax purposes purposes, and the Members agree not to take any action inconsistent with Board shall operate the Company's classification Company in such a manner as will preserve its treatment as a partnership for United States Federal U.S. federal income tax purposes.
Appears in 1 contract
Taxation as Partnership. The Members intend that the Company LLC shall be treated as a partnership for United States Federal federal income tax purposes and the Members agree not to take any action inconsistent with the CompanyLLC's classification as a partnership for United States Federal federal income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Burnham Pacific Properties Inc)
Taxation as Partnership. The Members intend It is the intention that the Company shall be treated as a partnership for 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 federal income tax purposes. The Members hereby authorize the Tax Matters Member to execute and file any and all documents necessary to effect such treatment as a partnership.
Appears in 1 contract
Samples: Limited Liability Company Agreement (MGT Capital Investments Inc)
