Partnership Classification. Notwithstanding anything in this Agreement to the contrary, the Tax Matters Partner in consultation with the Managing Member shall be authorized to interpret any provision of this Agreement in such manner necessary to prevent the Company or any entity owned by the Company from being treated as a publicly traded partnership taxable as a corporation for federal income tax purposes.
Appears in 3 contracts
Sources: Limited Liability Company Agreement (New Residential Investment Corp.), Limited Liability Company Agreement (Springleaf Holdings, LLC), Limited Liability Company Agreement (New Residential Investment Corp.)