EC Trust. The parties intend that the portion of the Trust consisting of the segregated pool of assets consisting of the EC Trust REMIC III Regular Interests (such portion of the Trust, the “EC Trust”) be treated as a grantor trust under Subpart E of Part 1 of subchapter J of the Code, as an “investment trust” under Treasury Regulations Section 301.7701-4(c) and as a “domestic trust” under Treasury Regulations Section 301.7701-7. The Class A-S, Class B and Class C Certificates represent ownership of the Class A-S Percentage Interest, the Class B Percentage Interest and the Class C Percentage Interest, respectively, in the Class A-S REMIC III Regular Interest, Class B REMIC III Regular Interest and Class C REMIC III Regular Interest, respectively. The Class PST Certificates represent ownership of the Class PST Components. For federal income tax purposes the Certificate Administrator shall treat the EC Trust as a grantor trust and shall treat each Holder of an EC Trust Certificate as the owner of the individual, underlying assets represented by any such EC Trust Certificate. In addition, to the fullest extent possible, ownership of an EC Trust Certificate shall be treated as direct ownership of the individual, underlying assets represented by such EC Trust Certificate for federal income tax reporting purposes.
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Samples: Pooling and Servicing Agreement (Morgan Stanley Bank of America Merrill Lynch Trust 2013-C7), Pooling and Servicing Agreement (Morgan Stanley Bank of America Merrill Lynch Trust 2013-C8), Pooling and Servicing Agreement (Morgan Stanley Bank of America Merrill Lynch Trust 2013-C7)
