Extract to table

Partnership classification of the International Feeder must be established prior to this date to support the structural integrity of the master-feeder arrangement

Partnership classification must be operative before non-U

7701-3(c)(1)(iii), an election specifying an effective date may not be filed more than 75 days before the requested effective date, and the election must be filed within 12 months after the requested effective date

PART III — CONSENT STATEMENT AND SIGNATURE(S) Consent of Each Member Under the instructions for IRS Form 8832, if an eligible entity has more than one owner, each owner must consent to the entity classification election

A copy of this Form 8832 must be attached to the entity's United States federal income tax return (Form 1065, U