Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.
Treatment for Tax Purposes. The group life insurance premium is covered by the provisions of Part II of the Danish Taxation of Pensions Act. Form of taxation: “Tax code 5 – Life insurance without right of deduction”.
Treatment for Tax Purposes. The Members hereby agree to disregard the Company as a separate entity for tax purposes.
Treatment for Tax Purposes. The Issuer shall treat the Notes as indebtedness of the Issuer and the Collateral as assets owned by the Issuer for purposes of all federal, state and local income taxes, unless and until otherwise required by an applicable taxing authority.
Treatment for Tax Purposes. It is the intention of the Member that the Company be treated as an entity disregarded from its owner for federal, state and local income tax purposes.
Treatment for Tax Purposes. For federal and applicable state and local income tax purposes, the Purchaser and Seller shall treat the Purchaser’s acquisition of the Acquired Interests as a sale and purchase of the assets of HoldCo and its Subsidiary.
Treatment for Tax Purposes. It is the intention of the Member that the Company be treated as an entity disregarded from its owner for federal, state and local income tax purposes. The Member is authorized to make all elections for tax or other purposes as it may deem necessary or appropriate.
Treatment for Tax Purposes. For so long as the Company has only one member, it is the intention of the Member that the Company be disregarded as a separate entity for federal, state and local tax purposes. If at any time the Company has more than one member, it shall be treated as a partnership for federal, state and local tax purposes.
Treatment for Tax Purposes. To the extent permitted by law, the Parties agree, solely for Tax purposes, to treat all payments made under this Article VIII, under any other indemnity provision contained in this Agreement, and for any misrepresentations or breach of warranties or covenants, as adjustments to the Aggregate Purchase Price for all Tax purposes, except to the extent the Law of a particular jurisdiction provides otherwise.
Treatment for Tax Purposes. The Partnership intends to be classified as a partnership for U.S. federal income tax purposes (and for state and local income tax purposes). Other than in connection with a Change of Control Transaction or Termination Transaction, the General Partner shall, for and on behalf of the Partnership, take all steps as may be reasonably required or advisable to maintain the Partnership’s classification as a partnership for U.S. federal income tax purposes.
