Common use of Disregarded Entity Clause in Contracts

Disregarded Entity. The parties and the Depositor intend that, for purposes of U.S. federal income, state and local income, and franchise taxes, so long as the Issuer has a single equity owner (as determined for U.S. federal income tax purposes), the Issuer will be treated as an entity disregarded as separate from such owner for U.S. federal income, state and local income, and franchise tax purposes.