Partnership Status. The parties intend to treat the Partnership as a partnership for U.S. federal income tax purposes.
Partnership Status. Each of the Company’s subsidiaries that is a partnership or a limited liability company, other than any entity for which a taxable REIT subsidiary election has been made (“Subsidiary Partnerships”), is properly classified either as a disregarded entity or as a partnership, and not as a corporation or as an association taxable as a corporation, for federal income tax purposes throughout the period from its formation through the date hereof, or, in the case of any Subsidiary Partnerships that have terminated, through the date of termination of such Subsidiary Partnerships.
Partnership Status. The Company will elect to be treated as a pass-through entity for purposes of federal and state income tax, and each Member covenants that it will make no election, declaration or statement on or in any tax return, tax filing, or any book or record maintained by it which is inconsistent with or detrimental to the Company's ongoing maintenance of partnership tax status (or as a single-member entity, if applicable).
Partnership Status. The Members intend, and the Company shall take no position inconsistent with, treating the Company as a partnership for United States federal, state and local income and franchise tax purposes.
Partnership Status. The Members intend that the Company shall be treated as a partnership for U.S. federal income, state and local income tax purposes to the extent such treatment is available, and agree to take such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent thereof.
Partnership Status. The Members intend to treat the Company as a partnership for U.S. federal income tax purposes and notwithstanding anything to the contrary herein, no election to the contrary shall be made.
Partnership Status. Starwood Realty Partnership is classified and taxable as a partnership for U.S. federal income tax purposes.
Partnership Status. 39. The Parties do not intend any of the provisions of this Partnership Agreement to be legally enforceable. However, this does not lessen the Parties’ commitment to this Agreement. All Parties are committed to fully implementing the Partnership Agreement in a transparent, consultative and accountable manner.
Partnership Status. Subject to Section 6.02, the Members intend that the Company shall be treated as a partnership for federal, state and local tax purposes to the extent such treatment is available, and agree to take such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent therewith; provided, however, that the Members intend that the Company shall not be a partnership (including a limited partnership) or joint venture, and that no Member shall be a partner or joint venturer of any other Member, for any purposes other than federal, state and local tax purposes, and this Agreement shall not be construed to suggest otherwise.
Partnership Status. The Members intend to treat, and the Company shall take no position inconsistent with treating, the Company as a partnership for United States federal, state and local income and franchise tax purposes prior to an Initial Public Offering of the Company. The Company shall not file any election pursuant to Regulations Section 301.7701-3(c) to be treated as an entity other than a partnership prior to any Initial Public Offering of the Company. The Company shall not elect, pursuant to Section 761(a) of the Code, to be excluded from the provisions of subchapter K of the Code.
