Borrower Tax Status. Permit the Borrower to become an association (or publicly traded partnership or taxable mortgage pool) taxable as a corporation for federal tax purposes at any time.
Borrower Tax Status. Make any election or otherwise take any action that would result in the Borrower becoming an association (or a publicly traded partnership or taxable mortgage pool) taxable as a corporation for U.S. federal income tax purposes.
Borrower Tax Status. The Borrower (A) is treated as disregarded as separate from its owner within the meaning of U.S. Treasury Regulation § 301.7701-3 for U.S. federal income tax purposes with such owner being a U.S. Person and (B) is not an association (or publicly traded partnership) taxable as a corporation for U.S. federal income tax purposes. The Borrower is not subject to any Tax in any jurisdiction outside the United States. The Borrower is not subject to any material amount of Taxes based on net income or gross receipts imposed by a state or local taxing authority. COVENANTS
Borrower Tax Status. The Servicer shall not take or cause any action to be taken that could result in the Borrower to (A) become treated as other than disregarded as separate from its owner within the meaning of U.S. Treasury Regulation § 301.7701-3 for U.S. federal income tax purposes with such owner being a U.S. Person or (B) become an association taxable as a corporation or a publicly traded partnership taxable as a corporation for U.S. federal income tax purposes. The Servicer shall ensure that the Borrower shall not become subject to any Tax in any jurisdiction outside the United States. The Servicer shall ensure that the Borrower shall not become subject to any material Taxes imposed by a state or local taxing authority. EXHIBIT V TERMINATION EVENTS Each of the following shall be a “Termination Event”:
