Fasit Administration. (a) The Holder of the Class O Certificate or, to the extent required by applicable Treasury Regulations, the Trustee, shall timely elect to treat the Trust as a FASIT under the Code and, if necessary, under applicable state law. Unless otherwise required by applicable Treasury Regulations, such election will be made on the appropriate federal or state tax returns for the taxable year of the Holder of the Class O Certificate in which the Certificates are issued or in any other taxable year as required by applicable Treasury Regulations.
Fasit Administration. 49 SECTION 10.02. Servicer and FASIT Administrator Indemnification. . . . . . . 52
Fasit Administration. Section 7.01
Fasit Administration. (a) The FASIT Administrator shall make an election to treat the Trust as a FASIT under the Code and, if necessary, under applicable state law. Such election will be made on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Notes and the Certificate are issued. For the purposes of the FASIT election in respect of the Trust, each of the Class A and Class B Notes shall be designated as the "regular interests" and the Certificate shall be designated as the sole "ownership interest" in the FASIT. The FASIT Administrator and the Trust shall not permit the creation of any "interests" (within the meaning of Section 860L of the Code) in the Trust other than the Notes and the Certificate unless they first receive an Opinion of Counsel at the expense of the party seeking the creation of such interests to the effect that such creation will not cause an Adverse FASIT Event.
Fasit Administration. 46 10.02. Compliance with FASIT Provisions; Further Assurances................49 ARTICLE XI. MISCELLANEOUS PROVISIONS
Fasit Administration. (a) The FASIT Administrator shall make an election to treat the Trust as a FASIT under the Code and, if necessary, under applicable state law. Such election will be made on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Notes, the Subordinated Interests and the Certificates are issued. For the purposes of the FASIT election in respect of the Trust, each of the Class A-1 Notes, the Class A-2 Notes, the Class A-3 Notes, the Class B Notes, the Fixed Rate Certificates, the Reserve Regular Interest, the YSA Regular Interest, Component X-0, Xxxxxxxxx X-0, Xxxxxxxxx X-0 and Component B shall be and hereby are designated as the "regular interests" and the Residual Certificate shall be designated as the sole "ownership interest" in the FASIT; provided, however, that if and to the extent that the Reserve Regular Interest, the YSA Regular Interest, the Fixed Rate Certificate and the Components are not treated as issued on the Closing Date for purposes of Section 860L of the Code, the designation of the Reserve Regular Interest, the YSA Regular Interest, the Fixed-Rate Certificates and the Components as "regular interests" in the FASIT represented by the Trust shall be effective immediately upon each such interests' being treated as issued for such purposes. The FASIT Administrator and the Trust shall not permit the creation of any "interests" (within the meaning of Section 860L of the Code) in the Trust other than the Notes, the Fixed Rate Certificates, the Reserve Regular Interest, the YSA Regular Interest, Component X-0, Xxxxxxxxx X-0, Xxxxxxxxx X-0 and Component B unless they first receive an Opinion of Counsel at the expense of the party seeking the creation of such interests to the effect that such creation will not cause an Adverse FASIT Event.
Fasit Administration
