Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, intend and agree to treat such Security as indebtedness of the Corporation for United States Federal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer Trust, to treat Preferred Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 3 contracts
Samples: Junior Subordinated Indenture (Everest Re Group LTD), Junior Subordinated Indenture (Everest Re Capital Trust), Junior Subordinated Indenture (First Coastal Capital Trust)
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, intend and agree to treat such Security as indebtedness of the Corporation Company for United States Federal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer Trust, to treat Preferred Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.tax
Appears in 2 contracts
Samples: Junior Subordinated Indenture (Everest Re Group LTD), Junior Subordinated Indenture (Everest Re Capital Trust Iii)
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such SecuritySecurity agree that for United States Federal, intend state and agree to treat local tax purposes it is intended that such Security as constitutes indebtedness of the Corporation Company for United States Federal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer a UnumProvident Trust, to treat Preferred Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 1 contract
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such SecuritySecurity agree that for United States Federal, intend state and agree to treat local tax purposes it is intended that such Security as constitutes indebtedness of the Corporation Company for United States Federal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer a Union Planters Trust, to treat Preferred Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 1 contract
Samples: Indenture (Union Planters Corp)
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, intend and agree to treat such Security as indebtedness of the Corporation Company for United States Federal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer Trust, to treat Preferred Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 1 contract
Samples: Junior Subordinated Indenture (CCC Capital Trust Ii)
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, intend and agree to treat such Security as indebtedness of the Corporation for United States Federal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer Trust, to treat Preferred Capital Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Capital Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 1 contract
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, intend and agree to treat such Security as indebtedness of the Corporation Company for United States Federal, state and local tax purposes and, with respect to Securities of a series initially issued to an Issuer a Trust, to treat Preferred Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 1 contract
Samples: Junior Subordinated Indenture (MRM Capital Trust Iii)
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, Security intend and agree to treat such Security as indebtedness of the Corporation Company for United States Federalfederal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer the Trust, to treat Preferred Capital Securities and Common Securities of such Issuer Trust (including but not limited to all payments and proceeds with respect to such Preferred Capital Securities and Common Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federalfederal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 1 contract
Samples: Indenture (Great West Life & Annuity Insurance Capital I)
Agreed Tax Treatment. Each Security issued hereunder shall provide that the Corporation Company and, by its acceptance or acquisition of a Security or a beneficial interest therein, the Holder of, and any Person that acquires a direct or indirect beneficial interest in, such Security, intend and agree to treat such Security as indebtedness debt of the Corporation Company for United States Federal, state and local tax purposes and, with respect to Securities of a series issued to an Issuer ONB Trust, to treat Preferred Capital Securities of such Issuer ONB Trust (including but not limited to all payments and proceeds with respect to such Preferred Capital Securities) as an undivided beneficial ownership interest in the Securities (and payments and proceeds therefrom, respectively) for United States Federalfederal, state and local tax purposes. The provisions of this Indenture shall be interpreted to further this intention and agreement of the parties.
Appears in 1 contract
Samples: Indenture (Onb Capital Trust Iv)