Common use of Federal Income Tax Treatment of the Trust Clause in Contracts

Federal Income Tax Treatment of the Trust. The parties hereto intend that the Seller, or other entity that is a REIT or a Qualified REIT Subsidiary, will at all times that the Notes are outstanding own a 100% Percentage Interest in the Trust Certificates; that the Seller will qualify for taxation as a REIT at all times that it is a Certificateholder; and that the Trust will be a Qualified REIT Subsidiary at all times the Notes are outstanding.