Treatment of Company. The Members intend that the Company be treated as a partnership, rather than as an association taxable as a corporation, for federal income tax purposes. No Member, Director or Officer may cause the Company to elect to be taxed as an association taxable as a corporation under Treasury Regulations Section 301.7701-3(c) or otherwise take any action that would result in the Company not being treated as a partnership for federal income tax purposes without the unanimous approval of the Members.
Treatment of Company. The Members intend that the Company will be treated as a partnership, rather than an association taxable as a corporation, for federal income tax purposes, and shall make no election, and no Member shall make any such election, under Treasury Regulations Section 301.7701-3(c).
Treatment of Company. . . 17 Section 8.4 Liquidation of Company Interests Upon Dissolution. . . . . . . . . . . . . 17
Treatment of Company. The Members intend that the Company be treated as a corporation, and not as a partnership, for Federal income tax purposes. In furtherance of the foregoing: (a) the Manager shall timely file an election on IRS Form 8832 of the Company to treat the Company as a corporation for Federal income tax purposes to be effective the date of formation of the Company; and (b) no Person, other than the Manager, shall be authorized to make any election by or on behalf of the Company to treat the Company as a partnership for Federal income tax purposes.
Treatment of Company. The Members intend that the Company will be treated as a partnership, rather than an association taxable as a corporation, for United States Federal income tax purposes and any applicable state tax purpose, and no Member shall file any election which would produce a different result. The Members intend that each wholly owned Subsidiary shall make an election to be treated as a "disregarded entity", and that each Subsidiary that is not wholly owned shall make an election to be treated as a partnership, in each case unless the Members determine otherwise, for United States federal and state income purposes. The Tax Matters Member shall cause the Company so to elect in a timely fashion; and the Members agree to execute such forms and documents as the Tax Matters Member may reasonably request in connection therewith.
Treatment of Company. Stock Purchased under an Exempt Loan.
