Common use of Characterization for Tax Purposes Clause in Contracts

Characterization for Tax Purposes. For United States federal and state income tax purposes, the Depositor's contribution of the Receivables to the Trust in exchange for interests in the Trust, and the sale by the Depositor of Class A Certificates (which includes Class A-1 Certificates, Class A-2 Certificates, Class A-3 Certificates, Class A-4 Certificates and Class A-5 Certificates) and Class I Certificates and the retention by the Depositor of the Class IC Certificate is intended to constitute the formation of a partnership (the "Tax Partnership") whose partners are the Class A Certificateholders, the Class I Certificateholders and the Class IC Certificateholder (which are hereinafter collectively referred to as the "Tax Partners"). This Tax Partnership shall continue in effect as provided in Paragraph 3 below. Pursuant to the final regulations adopting the "check-the-box" classification system for unincorporated organizations, the Servicer on behalf of the Tax Partners shall elect, in such manner as provided in such regulations, to treat the Trust as a partnership for federal income tax purposes, and each Tax Partner irrevocably agrees to be bound by such election. The Tax Partnership shall not be a partnership to any other extent or for any other purpose.

Characterization for Tax Purposes. For United States federal and state income tax purposes, the Depositor's contribution of the Receivables to the Trust in exchange for interests in the Trust, and the sale by the Depositor of Class A Certificates (which includes Class A-1 Certificates, Class A-2 Certificates, Class A-3 Certificates, Class A-4 Certificates and Class A-5 Certificates) and Class I Certificates and the retention by the Depositor of the Class IC Certificate is intended to constitute the formation of a partnership (the "Tax Partnership") whose partners are the Class A Certificateholders, the Class I Certificateholders and the Class IC Certificateholder (which are hereinafter collectively referred to as the "Tax Partners"). This Tax Partnership shall continue in effect as provided in Paragraph 3 below. Pursuant to the final regulations adopting the "check-the-box" classification system for unincorporated organizations, the Servicer on behalf of the Tax Partners shall elect, in such manner as provided in such regulations, to treat the Trust as a partnership for federal income tax purposes, and each Tax Partner irrevocably agrees to be bound by such election. The Tax Partnership shall not be a partnership to any other extent or for any other purpose.

Characterization for Tax Purposes. For United States federal and state income tax purposes, the Depositor's contribution of the Receivables to the Trust in exchange for interests in the Trust, and the sale by the Depositor of Class A Certificates (which includes Class A-1 Certificates, Class A-2 Certificates, Class A-3 Certificates, Class A-4 Certificates and Class A-5 A-4 Certificates) and Class I Certificates and the retention by the Depositor of the Class IC Certificate is intended to constitute the formation of a partnership (the "Tax Partnership") whose partners are the Class A Certificateholders, the Class I Certificateholders and the Class IC Certificateholder (which are hereinafter collectively referred to as the "Tax Partners"). This Tax Partnership shall continue in effect as provided in Paragraph 3 below. Pursuant to the final regulations adopting the "check-the-box" classification system systems for unincorporated organizations, the Servicer on behalf of the Tax Partners shall elect, in such manner as provided in such regulations, to treat the Trust as a partnership for federal and applicable state and local income tax purposes, and each Tax Partner partner irrevocably agrees to be bound by such election. The Tax Partnership shall not be a partnership to any other extent or for any other purpose.