United States Tax Classification. The Company shall not take any action that would cause it to cease to be classified as a corporation for United States federal income Tax purposes (including, without limitation, filing any United States Internal Revenue Service Form 8832 that would cause the Company to be taxed other than as a corporation for United States federal income Tax purposes).
United States Tax Classification. The Company intends to be treated as an association taxable as a corporation for U.S. federal, state and local income Tax purposes under Treasury Regulation section 301.7701-3 and under any corresponding provision of state or local law. The Company shall make a check-the-box election on Internal Revenue Service Form 8832 (or successor form) and any other necessary elections to be treated as a corporation for United States federal, state and local income Tax purposes, effective as of the Effective Date even if made thereafter.
United States Tax Classification. It is the intention of the parties hereto that the Partnership be treated as a partnership for United States federal, state and local income tax purposes. The Partnership shall not elect to be treated as other than a partnership under Treasury Regulations Section 301.7701-3(c) (or any corresponding applicable provisions of United States state or local law) unless the Series B Partner instructs the Partnership otherwise, in which case the Partnership shall make such election and timely file any required Internal Revenue Service Forms, as instructed by the Series B Partner. Subject to such election, neither the Partnership nor any Partner shall take any other action that may cause the Partnership to be treated as other than a partnership for United States federal, state and local income tax purposes.
