Trust Only. It is the intention of the Trustees to create only the relationship of Trustee and beneficiary between the Trustees and each Shareholder from time to time. It is not the intention of the Trustees to create a general partnership, limited partnership, joint stock association, corporation, bailment or any form of legal relationship other than a trust; provided, however, that the Trust intends be taxed as a “partnership” for U.S. federal and, where applicable, state, local and foreign income tax purposes. Except with respect to U.S. federal and, where applicable, state, local and foreign income tax purposes, nothing in this Declaration shall be construed to make the Shareholders, either by themselves or with the Trustees, partners or members of a joint stock association.
Appears in 3 contracts
Sources: Agreement and Declaration of Trust (Legg Mason Permal Global Active Strategies TEI Fund), Agreement and Declaration of Trust (Legg Mason Permal Global Active Strategies Fund), Agreement and Declaration of Trust (Legg Mason Permal Global Active Strategies Master Fund)