Partnership Status. The Members intend that the Company shall be treated as a partnership for U.S. federal income, state and local income tax purposes to the extent such treatment is available, and agree to take such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent thereof.
Appears in 6 contracts
Samples: The Contribution Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.), Tax Matters Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.), The Contribution Agreement (Lightstone Value Plus Real Estate Investment Trust, Inc.)
Partnership Status. The Members intend that the Company shall be treated as a partnership for U.S. federal incomefederal, state and local income tax purposes to the extent such treatment is available, and agree to take (or refrain from taking) such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent thereoftherewith, other than in connection with an IPO pursuant to Section 11.01.
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Endeavor Group Holdings, Inc.), Limited Liability Company Agreement (Endeavor Group Holdings, Inc.), Limited Liability Company Agreement (Endeavor Group Holdings, Inc.)
Partnership Status. The Members intend that the Company shall be treated as a partnership for U.S. federal incomeUnited States federal, state and local income tax purposes to the extent such treatment is available, and agree to shall take (or refrain from taking) such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent thereoftherewith.
Appears in 2 contracts
Samples: Operating Agreement (Hollinger Nci Holdings LLC), Operating Agreement (News Communications Inc)
Partnership Status. The Members intend that the Company shall be treated as a partnership for U.S. federal incomeUnited States federal, state and local income tax purposes to the extent such treatment is available, and agree to file all tax returns and take all tax positions in a manner consistent with such treatment. The Members agree to take such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent thereofwith such treatment.
Appears in 2 contracts
Samples: Operating Agreement (Hallmark Financial Services Inc), Operating Agreement (Hallmark Financial Services Inc)
Partnership Status. The Subject to Section 6.02, and Section 8.04(b), the Members intend that the Company shall be treated as a partnership for U.S. federal incomefederal, state and local income tax purposes to the extent such treatment is available, and agree to take such actions as may be necessary to receive and maintain such treatment and refrain from taking any actions inconsistent thereoftherewith.
Appears in 1 contract
Samples: Transaction Agreement (Apollo Global Management LLC)
