Section 7704(e) Relief Clause Samples

Section 7704(e) Relief. In the event that the Board determines the Company or any Series should seek relief pursuant to Section 7704(e) of the Code to preserve the status of the Company and each Series as a partnership for U.S. federal (and applicable state) income tax purposes, the Company, each Series and each Member shall agree to adjustments required by the tax authorities, and the Company and each applicable Series shall pay such amounts as required by the tax authorities, to preserve the status of the Company and each applicable Series as a partnership.