Section 7704(e) Relief. In the event that the Board determines the Company should seek relief pursuant to Section 7704(e) of the Code to preserve the status of the Company as a partnership for U.S. federal (and applicable state) income tax purposes, the Company and each Member shall agree to adjustments required by the tax authorities, and the Company shall pay such amounts as required by the tax authorities, to preserve the status of the Company as a partnership.
Appears in 367 contracts
Samples: Limited Liability Company Operating Agreement (Masterworks 007, LLC), Limited Liability Company Operating Agreement (Masterworks 104, LLC), Limited Liability Company Operating Agreement (Masterworks 057, LLC)
Section 7704(e) Relief. In the event that the Board Manager determines the Company should seek relief pursuant to Section 7704(e) of the Code to preserve the status of the Company as a partnership for U.S. federal (and applicable state) income tax purposes, the Company and each Member shall agree to adjustments required by the tax authorities, and the Company shall pay such amounts as required by the tax authorities, to preserve the status of the Company as a partnership.
Appears in 14 contracts
Samples: Limited Liability Company Operating Agreement (Vault Holding 1, LLC), Limited Liability Company Operating Agreement (Vault Holding 1, LLC), Limited Liability Company Operating Agreement (Vault Holding 1, LLC)
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 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.
Appears in 10 contracts
Samples: Limited Liability Company Operating Agreement (Masterworks Vault 1, LLC), Limited Liability Company Operating Agreement (Masterworks Vault 3, LLC), Limited Liability Company Operating Agreement (Masterworks Vault 5, LLC)
Section 7704(e) Relief. In the event that the Board of Directors determines the Company should seek relief pursuant to Section 7704(e) of the Code to preserve the status of the Company as a partnership for U.S. federal (and applicable state) income tax purposes, the Company and each Member shall agree to adjustments required by the tax authorities, and the Company shall pay such amounts as required by the tax authorities, to preserve the status of the Company as a partnership.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Och-Ziff Capital Management Group LLC), Limited Liability Company Agreement (Och-Ziff Capital Management Group LLC), Limited Liability Company Agreement (Och Daniel)
Section 7704(e) Relief. In the event that the Board Managing Member determines the Company should seek relief pursuant to Section 7704(e) of the Code to preserve the status of the Company as a partnership for U.S. federal (and applicable state) income tax purposes, the Company and each Member shall agree to adjustments required by the tax authorities, and the Company shall pay such amounts as required by the tax authorities, to preserve the status of the Company as a partnership.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Muscle Maker, Inc.)
