Common use of U.S. Tax Classification Clause in Contracts

U.S. Tax Classification. Seadrill T-15 has elected or prior to Closing will elect to be classified for United States federal income tax purposes as an entity disregarded as separate from Seller on a properly-completed Form 8832 filed with the Internal Revenue Service. This election has been or will be made with an effective date prior to Closing. Once this election has been made, neither Seller nor Seadrill T-15 will take any action to change the U.S. federal income tax classification of Seadrill T-15 from an entity disregarded as separate from Seller.

U.S. Tax Classification. Seadrill T-15 T-16 has elected or prior to Closing will elect to be classified for United States federal income tax purposes as an entity disregarded as separate from Seller on a properly-completed Form 8832 filed with the Internal Revenue Service. This election has been or will be made with an effective date prior to Closing. Once this election has been made, neither Seller nor Seadrill T-15 T-16 will take any action to change the U.S. federal income tax classification of Seadrill T-15 T-16 from an entity disregarded as separate from Seller.