Federal Income Tax Provisions. (a) For so long as the Trust has a single owner for federal income tax purposes, it will, pursuant to Treasury Regulations promulgated under section 7701 of the Code, be disregarded as an entity distinct from the Certificateholder for all federal income tax purposes. Accordingly, for federal income tax purposes, the Certificateholder will be treated as (i) owning all assets owned by the Trust, (ii) having incurred all liabilities incurred by the Trust, and (iii) all transactions between the Trust and the Certificateholder will be disregarded.
Appears in 8 contracts
Samples: Trust Agreement (Accredited Home Lenders Inc Mortgage Loan Trust 2004-1), Trust Agreement (Accredited Mortgage Loan Trust 2003-2), Trust Agreement (Accredited Mortgage Loan Trust 2003-3)