Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated among the Certificateholders as of the first day following the end of such quarter, in proportion to their Certificate Percentage Interest on such date, net income in an amount up to the sum any other amounts of income payable to the Certificateholders for such quarter. (b) Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Certificateholders in proportion to their Certificate Percentage Interest as of the first day following the end of such quarter in proportion to their Certificate Percentage Interest on such day. The Certificateholders are authorized to modify the allocations in this paragraph if necessary or appropriate, in their sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Certificateholders, or as otherwise required by the Code. ARTICLE THREE
Appears in 15 contracts
Samples: Trust Agreement (WFS Receivables Corp 3), Trust Agreement (WFS Receivables Corp), Trust Agreement (WFS Receivables Corp 3)
Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated among the Certificateholders as of the first day following the end of such quarter, in proportion to their Certificate Percentage Interest on such date, net income in an amount up to the sum any other amounts of income payable to the Certificateholders for such quarter.
(b) Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Certificateholders in proportion to their Certificate Percentage Interest as of the first day following the end of such quarter in proportion to their Certificate Percentage Interest on such day. The Certificateholders are authorized to modify the allocations in this paragraph if necessary or appropriate, in their sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Certificateholders, or as otherwise required by the Code. ARTICLE THREE.
Appears in 3 contracts
Samples: Trust Agreement (WFS Receivables Corp 2), Trust Agreement (WFS Receivables Corp 2), Trust Agreement (WFS Receivables Corp 3)
Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated among the Certificateholders as of the first day following the end of such quarter, in proportion to their Certificate Percentage Interest on such date, net income in an amount up to the sum of any other amounts of income payable to the Certificateholders for such quarter.
(b) Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Certificateholders in proportion to their Certificate Percentage Interest as of the first day following the end of such quarter in proportion to their Certificate Percentage Interest on such day. The Certificateholders are authorized to modify the allocations in this paragraph if necessary or appropriate, in their sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Certificateholders, or as otherwise required by the Code. ARTICLE THREE.
Appears in 2 contracts
Samples: Trust Agreement (WFS Financial 2005-2 Owner Trust), Trust Agreement (WFS Financial 2005-3 Owner Trust)
Federal Income Tax Allocations. (a) Net In the event that the Trust is treated as a partnership for Federal income tax purposes, net income of the Trust for any calendar quarter month as determined for federal Federal income tax purposes (and each item of income, gain, loss loss, credit and deduction entering into the computation thereof) shall be allocated to the extent of available net income, among the Certificateholders as of the first Record Date following the end of such month, in proportion to the Percentage Interest of their Certificates on such Record Date. Net losses of the Trust, if any, for any month as determined for Federal income tax purposes (and each item of income, gain, loss, credit and deduction entering into the computation thereof) shall be allocated among the Certificateholders as of the first day Record Date following the end of such quarter, month in proportion to their Certificate Percentage Interest on such date, net income in an amount up to Record Date until the sum any other amounts of income payable to the Certificateholders for such quarter.
(b) Net losses principal balance of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated Certificates is reduced to the Certificateholders in proportion to their Certificate Percentage Interest as of the first day following the end of such quarter in proportion to their Certificate Percentage Interest on such dayzero. The Certificateholders are Seller is authorized to modify the allocations in this paragraph if necessary or appropriate, in their its sole discretion, for the allocations to fairly reflect the economic income, gain, gain or loss and deduction to the Certificateholders, or as otherwise required by the Code. ARTICLE THREE.
Appears in 1 contract
Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated among the Certificateholders as of the first day following the end of such quarter, in proportion to their Certificate Percentage Interest on such date, net income in an amount up to the sum any other amounts of income payable to the Certificateholders for such quarter.
(b) Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Certificateholders in proportion to their Certificate Percentage Interest as of the first day following the end of such quarter in proportion to their Certificate Percentage Interest on such day. The Certificateholders are authorized to modify the allocations in this paragraph if necessary or appropriate, in their sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Certificateholders, or as otherwise required by the Code. ARTICLE THREETHREE TRUST CERTIFICATES AND TRANSFER OF INTERESTS
Appears in 1 contract
Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated among the Certificateholders as of the first day following the end of such quarter, in proportion to their Certificate Percentage Interest on such date, net income in an amount up to the sum any other amounts of income payable to the Certificateholders for such quarter.
(b) Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Certificateholders in proportion to their Certificate Percentage Interest as of the first day following the end of such quarter in proportion to their Certificate Percentage Interest ownership of the principal amount of Trust Certificates on such day. The Certificateholders are authorized to modify the allocations in this paragraph if necessary or appropriate, in their sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Certificateholders, or as otherwise required by the Code. ARTICLE THREE.
Appears in 1 contract