LLC Agreement. This Agreement shall be treated as part of the partnership agreement of OpCo 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 8 contracts
Samples: Tax Receivable Agreement (Bakkt Holdings, Inc.), Limited Liability Company Agreement (VPC Impact Acquisition Holdings), Tax Receivable Agreement
LLC Agreement. This Agreement shall be treated as part of the partnership agreement of OpCo as described in Section 761(c) of the Code and Sections 1.704-1.704- 1(b)(2)(ii)(h) and 1.761-1(c) of the Treasury Regulations.
Appears in 2 contracts
Samples: Employment Agreement (Sierra Income Corp), Employment Agreement (Medley Management Inc.)