Chapter 14 - EXHIBIT 14C • SAMPLE ELECTION UNDER THE BIPARTISAN BUDGET ACT OF 2015

• Jurisdiction: Colorado

EXHIBIT 14C • SAMPLE ELECTION UNDER THE BIPARTISAN BUDGET ACT OF 2015 SAMPLE ELECTION UNDER THE BIPARTISAN BUDGET ACT OF 2015

Sample provision for the appointment of the partnership representative under the Bipartisan Budget Act of 2015, and making the election under I.R.C. § 6221(b) not to be subject to the Bipartisan Budget Act of 2015.

(i) The Members hereby appoint __________ as the person with authority to act on behalf of the Company ("Company Representative") pursuant to Section 6223(a) of the Code (as amended by the Bipartisan Budget Act of 2015 (the "BBA")). The Company Representative shall not take any material action in its capacity as such without the approval of the Managers.¹ Any reference in this Section to a section of the Code is to such section as amended by the BBA and any corresponding provision of state or local law, as the same may be amended from time to time.

(ii) For any taxable year of the Company for which the Company qualifies to make an election under Section 6221(b) of the Code not to be subject to the BBA, the Company shall include with its income tax return for such taxable year an election under such section.

(iii) For any taxable year of the Company for which the Company does not qualify to make the election referenced in subsection (ii), the Managers shall determine whether the Company will make an election to have Section 6226 of the Code apply and imputed underpayments shall apply at the partner level to partners during the reviewed year. If the

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