LLC Agreement. This Agreement shall be treated as part of the LLC Agreement as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 40 contracts
Samples: Tax Receivable Agreement (Falcon's Beyond Global, Inc.), Tax Receivable Agreement (Bitcoin Depot Inc.), Tax Receivable Agreement (GSR II Meteora Acquisition Corp.)
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement partnership agreement of Holdings as described in Section 761(c) of the Internal Revenue Code of 1986, as amended, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 11 contracts
Samples: Tax Receivable Agreement, Tax Receivable Agreement, Tax Receivable Agreement (Malibu Boats, Inc.)
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement partnership agreement of the Company as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 7 contracts
Samples: Tax Receivable Agreement (Caliburn International Corp), Tax Receivable Agreement, Tax Receivable Agreement (UCP, Inc.)
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement partnership agreement of the Company as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(hl(b)(2)(ii)(h) and 1.761-1(cl(c) of the Treasury Regulations.
Appears in 4 contracts
Samples: Tax Receivable Agreement, Tax Receivable Agreement (Red Rock Resorts, Inc.), Tax Receivable Agreement (Red Rock Resorts, Inc.)
LLC Agreement. This Agreement shall be treated as part of the partnership agreement of the LLC Agreement as described in Section 761(c) of the Internal Revenue Code of 1986, as amended, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 3 contracts
Samples: Tax Receivable Agreement (Truett-Hurst, Inc.), Tax Receivable Agreement (Truett-Hurst, Inc.), Tax Receivable Agreement (Truett-Hurst, Inc.)
LLC Agreement. This To the extent this Agreement imposes obligations upon a particular Operating Subsidiary, this Agreement shall be treated as part of the relevant LLC Agreement as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h1.704−1(b)(2)(ii)(h) and 1.761-1(c1.761−1(c) of the Treasury Regulations.
Appears in 2 contracts
Samples: Tax Receivable Agreement (RCS Capital Corp), Tax Receivable Agreement (RCS Capital Corp)
LLC Agreement. This Agreement shall be treated as part of the Amended and Restated LLC Agreement as described in Section 761(c) of the Code Code, and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 2 contracts
Samples: Tax Receivable Agreement (57th Street General Acquisition Corp), Tax Receivable Agreement (57th Street General Acquisition Corp)
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement as described in Section 761(c) of the Code and Sections Treas. Reg. §§ 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations).
Appears in 2 contracts
Samples: Tax Matters Agreement (Baker Hughes a GE Co), Tax Matters Agreement (BAKER HUGHES a GE Co LLC)
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement partnership agreement of AHLLC as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 2 contracts
Samples: Tax Receivable Agreement (Adeptus Health Inc.), Tax Receivable Agreement (Adeptus Health Inc.)
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement as described in Section 761(c) of the Code and Treasury Regulations Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations).
Appears in 1 contract
Samples: Tax Receivable Agreement (Five Point Holdings, LLC)
LLC Agreement. This For purposes of the Code, and the Treasury Regulations promulgated thereunder, this Agreement shall be treated as part of the LLC Agreement as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury RegulationsRegulations promulgated thereunder.
Appears in 1 contract
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c1.761‑1(c) of the Treasury Regulations.
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LLC Agreement. This Agreement shall be treated as part of the LLC Agreement partnership agreement of AHLLC as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.. [The remainder of this page is intentionally blank]
Appears in 1 contract
Samples: Tax Receivable Agreement
LLC Agreement. This Agreement shall be treated as part of the LLC Agreement partnership agreement of AGH as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h1.704−1(b)(2)(ii)(h) and 1.761-1(c1.761−1(c) of the Treasury Regulations.
Appears in 1 contract
Samples: Tax Receivable Agreement (Artio Global Investors Inc.)
LLC Agreement. This Agreement shall be incorporated by reference and treated as part of the LLC Agreement as described in Section 761(c) of the Code and Sections 1.704-1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations. [The remainder of this page is intentionally blank.]
Appears in 1 contract
