Federal Income Tax Treatment of the Trust. (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 and (ii) having incurred all liabilities incurred by the Trust, and all transactions between the Trust and the Certificateholder will be disregarded.
Appears in 115 contracts
Samples: Trust Agreement (GM Financial Consumer Automobile Receivables Trust 2020-1), Trust Agreement (GM Financial Consumer Automobile Receivables Trust 2020-1), Trust Agreement (GM Financial Consumer Automobile Receivables Trust 2019-4)
Federal Income Tax Treatment of the Trust. (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 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 and 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 20 contracts
Samples: Trust Agreement (Triad Financial Special Purpose LLC), Trust Agreement (UPFC Auto Receivables Trust 2006-A), Trust Agreement (UPFC Auto Receivables Trust 2007-B)
Federal Income Tax Treatment of the Trust. (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 and Trust, (ii) having incurred all liabilities incurred by the Trust, Trust and (iii) all transactions between the Trust and the Certificateholder will be disregarded.
Appears in 4 contracts
Samples: Trust Agreement (AFS SenSub Corp.), Trust Agreement (AFS SenSub Corp.), Trust Agreement (AFS SenSub Corp.)
Federal Income Tax Treatment of the Trust. (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 separate from the Certificateholder such owner for all federal income tax purposes. Accordingly, for federal income tax purposes, the Certificateholder owner will be treated as (i) owning all assets owned by the Trust and (ii) having incurred all liabilities incurred by the Trust, and all transactions between the Trust and the Certificateholder owner will be disregarded.
Appears in 1 contract
Samples: Trust Agreement (Efcar, LLC)
Federal Income Tax Treatment of the Trust. (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 and (ii) having incurred all liabilities incurred by the Trust, and (iii) all transactions between the Trust and the Certificateholder will be disregarded.
Appears in 1 contract
Samples: Trust Agreement (AFS SenSub Corp.)
Federal Income Tax Treatment of the Trust. (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 and Trust, (ii) having incurred all liabilities incurred by the Trust, and (iii) all transactions between the Trust and the Certificateholder will be disregardeddisregarded .
Appears in 1 contract
Samples: Trust Agreement (Americredit Financial Services Inc)
Federal Income Tax Treatment of the Trust. (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 and 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 1 contract
Samples: Trust Agreement (Americredit Financial Services Inc)