Common use of Federal Income Tax Provisions Clause in Contracts

Federal Income Tax Provisions. (a) The Issuing Entity will be wholly owned by the Certificateholder, which as of the Closing Date is the Depositor. The Depositor has made an election to be treated as a “real estate investment trust” (a “REIT”) under Section 856 of the Code. As such, the Depositor, as the sole Certificateholder, will be regarded as (i) owning all assets owned by the Issuing Entity and (ii) having incurred all liabilities incurred by the Issuing Entity, and all transactions between the Issuing Entity and the Depositor will be disregarded.

Federal Income Tax Provisions. (a) [The Issuing Entity will be wholly owned by the Certificateholder, which as of the Closing Date is the Depositor. The Depositor has made an election to be treated as a “real estate investment trust” (a “REIT”) under Section 856 of the Code. As such, the Depositor, as the sole Certificateholder, will be regarded as (i) owning all assets owned by the Issuing Entity and (ii) having incurred all liabilities incurred by the Issuing Entity, and all transactions between the Issuing Entity and the Depositor will be disregarded.