Partnership Classification for Tax Purposes. Each Partner recognizes, agrees and intends that, for U.S. federal and state income tax purposes, the Partnership shall be classified as a partnership. The General Partner shall not permit the Partnership to elect, and the Partnership shall not elect, to be treated as an association taxable as a corporation for U.S. federal, state or local income tax purposes under Treasury Regulations Section 301.7701-3(a) or under any corresponding provision of state or local law.
Appears in 7 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement (Oaktree Capital Group, LLC), Limited Partnership Agreement (Oaktree Capital Group, LLC)
