Classification for Tax Purposes. Notwithstanding anything contained herein to the contrary, the Member and the Board of Managers recognize and intend that, for federal income tax purposes, the Member shall constitute the single owner of the Company and the Company shall constitute an entity with a single owner, which for federal income tax purposes is disregarded as an entity separate from the Member in accordance with Section 301.7701-3(b)(1)(ii) of the Treasury Regulations. The Member and the Board of Managers will not make any election or take any action which would cause the Company to be classified as an association, a corporation or a partnership for federal income tax purposes.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Shellpoint Mortgage Acceptance LLC), Limited Liability Company Agreement (BNP Paribas Mortgage Securities LLC), Limited Liability Company Agreement (Cendant Mortgage Capital LLC)
Classification for Tax Purposes. Notwithstanding anything contained herein to the contrary, the Member and the Board of Managers Directors recognize and intend that, for federal income tax purposes, the Member shall constitute the single owner of the Company and the Company shall constitute an entity with a single owner, which for federal income tax purposes is disregarded as an entity separate from the Member in accordance with Section 301.7701-3(b)(1)(ii) of the Treasury Regulations. The Member and the Board of Managers Directors will not make any election or take any action which would cause the Company to be classified as an association, a corporation or a partnership for federal income tax purposes.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (American Home Mortgage Securities LLC), Limited Liability Company Agreement (New Century Mortgage Securities LLC)
Classification for Tax Purposes. Notwithstanding anything contained herein to the contrary, the Member and the Board of Managers Directors recognize and intend that, for federal income tax purposes, the Member shall constitute the single owner of the Company and the Company shall constitute an entity with a single owner, which for federal income tax purposes is disregarded as an entity separate from the Member in accordance with Section 301.7701-301.7701 3(b)(1)(ii) of the Treasury Regulations. The Member and the Board of Managers Directors will not make any election or take any action which would cause the Company to be classified as an association, a corporation or a partnership for federal income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Agreement (National City Mortgage Capital LLC)
