Federal Tax Disclosure. The Underwriters will have received an opinion of Cravath, Swaine & Xxxxx LLP, special federal tax and ERISA counsel to Citibank, in form and substance satisfactory to the Representative, to the effect that the statements relating to United States law contained under the heading “Tax Matters” in the Prospectus accurately describe the material federal income tax consequences to holders of the Notes and the statements contained under the heading “Benefit Plan Investors” in the Prospectus, to the extent that they constitute statements of matters of law or legal conclusions with respect thereto, accurately describe the material consequences to holders of the Notes under ERISA.
Federal Tax Disclosure. The Underwriters will have received an opinion of Cravath, Swaine & Xxxxx LLP, special federal tax and ERISA counsel to the Banks, in form and substance satisfactory to the Representative, to the effect that the statements relating to United States law contained under the heading “Tax Matters” in the Prospectus accurately describe the material federal income tax consequences to holders of the Class 200[•]-[A][B][C][•] Notes and the statements contained under the heading “Benefit Plan Investors” in the Prospectus, to the extent that they constitute statements of matters of law or legal conclusions with respect thereto, accurately describe the material consequences to holders of the Class 200[•]-[A][B][C][•] Notes under ERISA.
Federal Tax Disclosure. The Underwriters will have received an opinion of Cxxxxxx, Swaine & Mxxxx LLP, special federal tax and ERISA counsel to Citibank (South Dakota), in form and substance satisfactory to the Representative, to the effect that the statements relating to United States law contained under the heading “Tax Matters” in the Prospectus accurately describe the material federal income tax consequences to holders of the Class 2009-A1 Notes and the statements contained under the heading “Benefit Plan Investors” in the Prospectus, to the extent that they constitute statements of matters of law or legal conclusions with respect thereto, accurately describe the material consequences to holders of the Class 2009-A1 Notes under ERISA.
Federal Tax Disclosure. The Underwriters will have received an opinion of Xxxxxx, Xxxxxxxxxx & Xxxxxxxxx LLP, special federal tax counsel to Citibank, in form and substance satisfactory to the Representative, to the effect that (A) although the discussion set forth in the Prospectus under the heading “Tax Matters” does not purport to discuss all possible U.S. federal income tax considerations relating to an investment in the Notes, such discussion constitutes, in all material respects, a fair and accurate summary of the U.S. federal income tax consequences of the purchase, ownership and disposition of a beneficial interest in the Notes and (B) the statements contained under the heading “Benefit Plan Investors” in the Prospectus, to the extent that they constitute statements of matters of law or legal conclusions with respect thereto, accurately describe the material consequences to holders of the Notes under XXXXX.
