TAXATION STATUS. At all times that the Company has only one Member (who owns 100% of the limited liability company interests in the Company), it is the intention of the Member that the Company be disregarded for federal, state, local and foreign income tax purposes. Each Series shall be, to the extent permissible by applicable law, treated as a separate partnership for federal and applicable State tax purposes.
Appears in 7 contracts
Samples: Purchase Agreement, Purchase Agreement, Purchase Agreement
TAXATION STATUS. At all times that the Company has only one Member (who owns 100% of the limited liability company interests in the Company), it is the intention of the Member that the Company be disregarded for federal, state, local and foreign income tax purposes. Each Series shall be, make its own decision to the extent permissible by applicable law, treated be taxed as either a separate partnership for federal and applicable State tax purposesor corporation.
Appears in 1 contract
Samples: Limited Liability Company Agreement (Freeport Holdings Series LLC)