Alternative Characterization. The Issuer acknowledges that the American Jobs Creation Act of 2004 (the “Jobs Act”) repealed the provisions of the Code governing FASITs. In the event that the Internal Revenue Service issues guidance in the form of a Notice, Revenue Procedure, Revenue Ruling, or Private Letter Ruling providing for FASITs existing prior to October 22, 2004 to terminate and/or cease issuing regular interests, then it is the intent of the parties hereto that, for federal income tax purposes, (i) the Trust Estate be disregarded as an entity separate from RFS Holding L.L.C. and (ii) the Notes be treated as debt.
Appears in 9 contracts
Samples: GE Capital Credit Card Master Note Trust, GE Capital Credit Card Master Note Trust, GE Capital Credit Card Master Note Trust
