Common use of Grantor Trust Status Clause in Contracts

Grantor Trust Status. It is the intent of the parties hereto that the Trust be treated as a grantor trust for federal income tax purposes under subpart E, part I of subchapter J of the Internal Revenue Code and not as an association taxable as a corporation, a partnership, or any other “business entity” (within the meaning of Treasury Regulation § 301.7701-2(a)), and the provisions of this Trust Agreement shall be interpreted and applied consistently therewith. The Issuer Loan Trustee covenants that it shall perform, and cause any agent of the Issuer Loan Trustee to perform, its obligations hereunder in a manner so as to maintain the status of the trust created hereunder as a grantor trust for federal income tax purposes under subpart E, part I of subchapter J of the Internal Revenue Code and not as an association taxable as a corporation, a partnership, or any other “business entity” (within the meaning of Treasury Regulation § 301.7701-2(a)), to the extent that maintaining such status and avoiding such taxes are reasonably within the control of the Issuer Loan Trustee.

Grantor Trust Status. It is the intent of the parties hereto that the Trust be treated as a grantor trust for federal income tax purposes under subpart E, part I of subchapter J of the Internal Revenue Code and not as an association taxable as a corporation, a partnership, or any other “business entity” (within the meaning of Treasury Regulation § 301.7701-2(a)), ) and the provisions of this Trust Agreement shall be interpreted and applied consistently therewith. The Issuer Depositor Loan Trustee covenants that it shall perform, perform and cause any agent of the Issuer Depositor Loan Trustee to perform, its obligations hereunder in a manner so as to maintain the status of the trust created hereunder as a grantor trust for federal income tax purposes under subpart E, part I of subchapter J of the Internal Revenue Code and not as an association taxable as a corporation, a partnership, or any other “business entity” (within the meaning of Treasury Regulation § 301.7701-2(a)), to the extent that maintaining such status and avoiding such taxes are reasonably within the control of the Issuer Depositor Loan Trustee.