Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 27 contracts
Samples: Loan and Servicing Agreement (Carlyle GMS Finance, Inc.), Loan and Servicing Agreement (Carlyle GMS Finance, Inc.), Loan and Servicing Agreement (Solar Senior Capital Ltd.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 26 contracts
Samples: Loan and Servicing Agreement (Business Development Corp of America), Loan and Servicing Agreement (FS Investment Corp II), Loan and Servicing Agreement (FS Investment CORP)
Disregarded Entity. The Servicer shall cause the Borrower will to be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), ) and shall cause that neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 17 contracts
Samples: Loan and Servicing Agreement (FS KKR Capital Corp), Loan and Servicing Agreement (Fifth Street Finance Corp), Loan and Servicing Agreement (Corporate Capital Trust, Inc.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b3(b)(ii), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 6 contracts
Samples: Loan and Servicing Agreement (Franklin BSP Capital Corp), Loan and Servicing Agreement (Franklin BSP Capital Corp), Loan and Servicing Agreement (Franklin BSP Capital Corp)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Regulations Section 301.7701-3(b3(b)(ii), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Regulations Section 301.7701-3(c).
Appears in 3 contracts
Samples: Loan and Servicing Agreement (First Eagle Private Credit Fund), Loan and Servicing Agreement (AGTB Private BDC), Loan and Security Agreement (Stepstone Private Credit Fund LLC)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, being treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 3 contracts
Samples: Loan and Servicing Agreement (Solar Capital Ltd.), Loan and Servicing Agreement (Solar Capital Ltd.), Loan and Servicing Agreement (Solar Senior Capital Ltd.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b)for U.S. federal income tax purposes, and neither none of the Borrower Borrower, the Equityholder, nor any other Person on its their behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 2 contracts
Samples: Loan and Servicing Agreement (FS Investment Corp II), Loan and Servicing Agreement (FS KKR Capital Corp)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to beelection, or take any other action that is reasonably likely would cause the Borrower, to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c).
Appears in 2 contracts
Samples: Loan and Servicing Agreement (North Haven Private Income Fund LLC), Loan and Servicing Agreement (North Haven Private Income Fund LLC)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in may cause the Borrower being, to be treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c)owner.
Appears in 2 contracts
Samples: Loan and Servicing Agreement (Franklin BSP Lending Corp), Loan and Servicing Agreement (Business Development Corp of America)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b301.7701‐3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c301.7701‐3(c).
Appears in 1 contract
Samples: Loan and Servicing Agreement (Carlyle Credit Solutions, Inc.)
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Regulations Section 301.7701-3(b301.7701‑3(b)(ii), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, be treated as other than an entity disregarded from its owner under Treasury Regulation Regulations Section 301.7701-3(c301.7701‑3(c).
Appears in 1 contract
Disregarded Entity. The Borrower will be disregarded as an entity separate from its owner pursuant to Treasury Regulation Section 301.7701-3(b301.7701‑3(b), and neither the Borrower nor any other Person on its behalf shall make an election to be, or take any other action that is reasonably likely to result in the Borrower being, treated as other than an entity disregarded from its owner under Treasury Regulation Section 301.7701-3(c301.7701‑3(c).
Appears in 1 contract
Samples: Loan and Servicing Agreement (KKR Real Estate Finance Trust Inc.)
