Taxation as a Partnership. It is the intention of the Members that the Company be classified as a partnership for U.S. federal income tax purposes. No election shall be made by the Company or any Member 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 Regulations Section 301.7701-3; provided, that the foregoing restrictions shall not apply to any ownership arrangement with respect to Oil and Gas Properties.
Appears in 4 contracts
Samples: Limited Liability Company Agreement (Exco Resources Inc), Limited Liability Company Agreement (Harbinger Group Inc.), Limited Liability Company Agreement (Exco Resources Inc)
