Examples of Partnership Election in a sentence
If the Board determines to cause the Company to make a Partnership Election, to the extent that the Company has Members that are subject to tax on UBTI, the Company shall use reasonable best efforts, based on advice of the Company’s tax advisers, to effect the Partnership Election and conduct the operations of the Company so as to not create a material amount of UBTI for those affected Members.
A failure of the MC Partners to provide a Partnership Election prior to the expiration of such thirty (30) day period shall be deemed to be an Opt Out Election.
Upon notification by any Investor that any Group Company should elect to be classified as a partnership or disregarded entity for U.S. federal income tax purposes (the “Partnership Election”), the Company shall make, or shall cause to be made, the “Partnership Election” by filing, or by causing to be filed, Internal Revenue Service Form 8832 (or any successor form), and the Company shall not permit the Partnership Election to be terminated or revoked without the written consent of the relevant Investor.
Here we propose a simpler approach, based on the above reduction of LCC into E PDL; and moreover they allow for better plan search methods.
Additionally, at any time, the Company or any of its Subsidiaries shall, if so requested by GCT, make an election to be classified as a partnership or a disregarded entity, as the case may be, for United States federal income tax purposes (a "Partnership Election") by filing an election on Internal Revenue Service Form 8832 (or any successor form), all of which elections shall be effective as of a date specified by GCT.
Upon notification by Xxxxxxx Sachs to the Company that the Company or one or more of its Subsidiaries should elect to be classified as partnerships or disregarded entities for United States federal income tax purposes (“Partnership Election”), the Company shall make, or shall cause to be made, the Partnership Election by filing, or by causing to be filed, Internal Revenue Service Form 8832.
The Company shall not permit the Partnership Election to be terminated or revoked without the written consent of the Holders.
True and correct copies of the election filed by the Company to elect to be treated as a "special partnership" (the "Special Partnership Election") under Subchapter K of Chapter 2 of Subtitle A of the Puerto Rico Internal Revenue Code of 1994, as amended (the "PR Code"), and the reply received from the Puerto Rico Treasury Department concerning such election.
Neither the Tax Partnership Election nor any tax partnership election pursuant to Section 7.04(b) creates or implies a general partnership between F&F and The9 or any other applicable parties for any purpose.
Where a valid Telesat Partnership Election is still required in order to receive Telesat Partnership Units as Transaction Consideration, it has been assumed that no such valid Telesat Partnership Election can be assured and as a result Telesat Public Shares will be issued as Transaction Consideration.