Partnership Election. The Members elect that the LLC be taxed as a partnership and not as an association taxable as a corporation.
Partnership Election. The Company represents and warrants that it has not taken any action inconsistent with its or ReNew India’s treatment as a corporation for U.S. federal income tax purposes, including the filing of an election to be classified other than as a corporation. Neither the Company nor ReNew India shall take any action inconsistent with the treatment of the Company and ReNew India as a corporation for U.S. federal income tax purposes and neither shall elect to be treated as an entity other than a corporation for U.S. federal income tax purposes unless the Investors unanimously agree that such an election should be made.
Partnership Election. The Members intend that the Company will be taxed as a partnership for United States federal, state and local income tax purposes. The Tax Matters Member will accordingly not elect to classify the Company as other than a partnership for federal income tax purposes under Section 7701 of the Code and the applicable Regulations. The Members agree not to elect to be excluded from the application of Subchapter K of Chapter 1 of Subtitle A of the Code or any similar state statute and agree not to elect for the Company to be treated as a corporation, or an association taxable as a corporation, under the Code or any similar state statute.
Partnership Election. The tax partnership provisions contained in Exhibit G to the Operating Agreement shall govern the relationship of the parties under this Agreement for tax purposes. Said tax partnership provisions shall be effective as of the date of this Agreement.
Partnership Election. (a) GCT shall have the right to make, or cause the Company or any of its Subsidiaries to make, all tax elections of the Company or such Subsidiary, which GCT deems appropriate. Additionally, at any time, the Company or any of its Subsidiaries shall, if so requested by GCT, make an election to be classified as a partnership or a disregarded entity, as the case may be, for United States federal income tax purposes (a "Partnership Election") by filing an election on Internal Revenue Service Form 8832 (or any successor form), all of which elections shall be effective as of a date specified by GCT. The Partnership Election may be signed by any Director or Officer of the Company who is authorized by the Board of Directors to sign on behalf of the Company.
Partnership Election. (a) At any time, GCT may notify -------------------- the Company that GCT wants the Company to file an election to be classified as a partnership for U.S. Federal income tax purposes, in which event the Company shall promptly file an election on Internal Revenue Service Form 8832 (or any successor form) to be classified as a partnership for U.S. Federal income tax purposes (a "Partnership Election"). The Partnership Election may be signed by any Officer of the Company who is authorized by the Board of Directors to sign on behalf of the Company. If the Company files a Partnership Election, the parties hereto agree to reasonably cooperate to amend this Agreement to provide for the maintenance of capital accounts in accordance with applicable U.S. Treasury Regulations.
Partnership Election. Prior to the ------------------------------------ Closing Date, Hercules and Mallinckrodt shall cause Tastemaker B.V. to make an election complying with the requirements of Treasury Regulations Section 301.7701-3(c) to be classified, effective as of a date prior to the Closing Date, as a partnership for United States federal income Tax purposes. 5.11
Partnership Election. Effective as of the date hereof, Circuit will elect to be treated as a partnership for federal income tax purposes.
Partnership Election. Within thirty (30) days of receipt of the Offer Notice, the General Partner may elect to have the Partnership (or any other Person designated by the General Partner) purchase all or any portion of the Offered Units at the price and on the other terms set forth in the Offer Notice, by delivering written notice of such election to the Transferring Partner and each other Partner holding Units of the class and/or series of Units to be Transferred by the Transferring Partner (the “Eligible Partners”).
