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
Sources: Tax Receivable Agreement (Bakkt Holdings, Inc.), Merger 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
Sources: Agreement and Plan of Merger (Sierra Income Corp), Agreement and Plan of Merger (Medley Management Inc.)