Partnership for U.S. Federal Tax Purposes. As long as the Company remains a Delaware limited liability company with at least two (2) members, the Members agree to treat the Company as a partnership and to treat all Membership Interests as interests in such partnership for U.S. federal income tax purposes and no Member shall take any position inconsistent with this characterization in any tax return or otherwise to the extent consistent with applicable law.
Appears in 5 contracts
Samples: Limited Liability Company Operating Agreement (Sierra Income Corp), Limited Liability Company Agreement (KCAP Financial, Inc.), Limited Liability Company Operating Agreement (Medley Capital Corp)
Partnership for U.S. Federal Tax Purposes. As long as the Company remains a Delaware limited liability company with at least two (2) memberscompany, the Members parties agree to treat the Company as a partnership and to treat all Membership Interests Units as interests in such partnership for U.S. federal income tax purposes and no Member party shall take any position inconsistent with this characterization in any tax return or otherwise to the extent consistent with applicable law.
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (Eagle Point Credit Co LLC), Limited Liability Company Operating Agreement (Garrison Capital LLC)
Partnership for U.S. Federal Tax Purposes. As long as the Company remains a Delaware limited liability company with at least two (2) memberscompany, the Members parties agree to treat the Company as a partnership and to treat all Membership Interests Units as interests in such partnership for U.S. federal income tax purposes and no Member party shall take any position inconsistent with this characterization in any tax return or otherwise to the extent consistent with applicable law.. ARTICLE XI
Appears in 2 contracts
Samples: Limited Liability Company Operating Agreement (NexPoint Capital, LLC), Limited Liability Company Operating Agreement (WhiteHorse Finance, LLC)
Partnership for U.S. Federal Tax Purposes. As long as the Company remains a Delaware limited liability company with at least two (2) memberscompany, the Members parties agree to treat the Company as a partnership and to treat all Membership Interests Units as interests in such partnership for U.S. federal income tax Tax purposes and no Member party shall take any position inconsistent with this characterization in any tax Tax return or otherwise to the extent consistent with applicable law.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (EP Income Co LLC)
