Common use of Tax Partnership Clause in Contracts

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Member, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Memberin accordance with Section 8.2 and Section 8.4(b), neither the Company nor any Member shall make an election for the Company Partnership to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing each Member, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Memberin accordance with Section 7.6, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal Federal income tax purposes. Unless otherwise approved by the Managing MemberBoard pursuant to Section 5.1(c)(xxix), neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state State Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Member, neither Neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Member, neither Neither the Company nor any Member shall make an election for the Company Partnership to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention intent of the Members that the Company be classified treated as a partnership for U.S. federal income tax purposes. Unless otherwise approved purposes and, to the extent permitted by the Managing Memberapplicable law, for state and local franchise and income tax purposes and neither the Company nor any Member shall make file an election for to classify the Company as an association taxable as a corporation for federal income tax purposes. Notwithstanding the foregoing, it is agreed that this Section 7.4 shall not be applicable if the tax status of the Company were to be excluded from reclassified as a result of a merger or other transaction approved by the application Board of Managers in accordance with the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3terms hereof.

Tax Partnership. It Except as provided in Section 7.6, it is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Member, neither Neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved determined by the Managing MemberSteering Committee, neither the Company nor any Member shall make an election for the Company partnership to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Section §301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Memberin accordance with Section 8.5(b), neither the Company nor any Member shall make an election for the Company Partnership to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Member, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing MemberManager, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing MemberBoard, neither the Company nor any Member shall make an election for or take any other action causing the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3. Upon Manager unanimous approval the Company may elect to be taxed as a corporation.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal Federal income tax purposes. Unless otherwise approved by the Managing MemberBoard pursuant to Section 5.1(d)(xiii), neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state State Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Member, neither Neither the Company nor any Member shall make an election for the Company partnership to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Section §301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing each Member, neither the Company nor any Member shall make an election for the Company Partnership to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. United States federal income tax purposes. Unless otherwise approved by requiring the Managing Memberapproval of the Board pursuant to Section 4.3, neither the Company nor shall not cause any Member shall Company Entity to make or cause to be made an election for the Company (i) to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state State Law or (ii) to be classified as other than a partnership or a disregarded entity pursuant to Treasury Regulation Regulations Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing Memberapproved, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law law or to be classified as other than a partnership pursuant to Treasury Regulation Regulations Section 301.7701-3, and no provision of this Agreement (including Section 2.7) shall be construed to sanction or approve such an election.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax Tax purposes. Unless otherwise approved by the Managing Member, neither Neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a single partnership for U.S. federal Federal and applicable state and local income tax purposes. Unless otherwise approved by all of the Managing MemberMembers, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter Subchapter K of chapter Chapter 1 of subtitle Subtitle A of the Code or any similar or corresponding provisions of applicable state or local Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved by the Managing MemberSponsor, neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.

Tax Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. Unless otherwise approved (i) by the Managing MemberSponsor and (ii) in accordance with Section 8.5(b)(xiii), neither the Company nor any Member shall make an election for the Company to be excluded from the application of the provisions of subchapter K of chapter 1 of subtitle A of the Code or any similar provisions of applicable state Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3.