Tax Partnership. It is the intention of the Partners that the Partnership be classified as a partnership for U.S. federal tax purposes. Neither the Partnership nor any Partner shall make an election for the Partnership or any Series 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 or local law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3 or any similar provision of state or local law.
Appears in 8 contracts
Samples: Contribution Agreement (Enbridge Energy Partners Lp), Agreement (Enbridge Energy Partners Lp), Agreement (Enbridge Energy Partners Lp)
Tax Partnership. It is the intention of the Partners Members that the Partnership Company be classified as a partnership for U.S. federal income tax purposes. Neither the Partnership Company nor any Partner Member shall make an election for the Partnership or any Series 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 or local law Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3 or any similar provision of state or local law3.
Appears in 5 contracts
Samples: Limited Liability Company Agreement (Oasis Midstream Partners LP), Membership Interest Purchase Agreement (LMP Automotive Holdings, Inc.), Membership Interest Purchase Agreement (LMP Automotive Holdings, Inc.)
Tax Partnership. It is the intention of the Partners that the Partnership be classified as a partnership for U.S. federal tax purposes. Neither the Partnership nor any Partner shall make an election for the Partnership or any Series 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 or local law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3 or any similar provision of state or local law.
Appears in 2 contracts
Samples: General Partnership Agreement (Regency Energy Partners LP), General Partnership Agreement (Regency Energy Partners LP)
Tax Partnership. It is the intention of the Partners Members that the Partnership Company be classified as a partnership for U.S. federal income tax purposes. Neither Unless otherwise approved in accordance with Section 8.5(a), neither the Partnership Company nor any Partner Member shall make an election for the Partnership or any Series 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 or local law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3 or any similar provision of state or local law3.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Laredo Petroleum - Dallas, Inc.), Limited Liability Company Agreement (Laredo Petroleum, Inc.)
Tax Partnership. It is the intention of the Partners Members that the Partnership Company be classified as a partnership for U.S. federal income tax purposes. Neither Unless otherwise determined by the Partnership Managing Member, neither the Company nor any Partner Member shall make an election for the Partnership or any Series 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 or local law or to be classified as other than a partnership pursuant to Treasury Regulation Section §301.7701-3 or any similar provision of state or local law3.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Caesars Acquisition Co), Limited Liability Company Agreement (CAESARS ENTERTAINMENT Corp)
Tax Partnership. It is the intention of the Partners that the Partnership be classified as a partnership for U.S. federal income tax purposes. Neither Unless otherwise approved by the General Partner, neither the Partnership nor any Partner shall make an election for the Partnership or any Series 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 or local law Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3 or any similar provision of state or local law3.
Appears in 1 contract
Tax Partnership. It is the intention of the Partners that the Partnership be classified as a partnership for U.S. federal income tax purposes. Neither Unless otherwise approved by the General Partner, neither the Partnership nor any Partner shall make an election for the Partnership or any Series 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 or local law Law or to be classified as other than a partnership pursuant to Treasury Regulation Section 301.7701-3 or any similar provision of state or local law.3. GPM PETROLEUM LP SECOND AMENDED AND RESTATED AGREEMENT OF LIMITED PARTNERSHIP
Appears in 1 contract
