Common use of Intended Tax Characterization Clause in Contracts

Intended Tax Characterization. The parties hereto agree that it is their mutual intent that, for all applicable tax purposes, the Class A Notes and the Class B Notes shall constitute indebtedness and that for all applicable tax purposes, accordingly, the Trust shall be treated as sole and exclusive owner of the Pledged Property. Further, each party hereto, and each Noteholder (by receiving and holding a Note), hereby covenants to every other party hereto and the Noteholders to treat the Class A Notes and the Class B Notes as indebtedness for all applicable tax purposes in all tax filings, reports and returns and otherwise, and further covenants that neither it nor any of its Affiliates will take or participate in the taking of, or permit to be taken, any action that is inconsistent with the treatment of the Class A Notes or of the Class B Notes as indebtedness for tax purposes. All successors and assigns of the parties hereto shall be bound by the provisions hereof.

Intended Tax Characterization. The parties hereto agree that ----------------------------- it is their mutual intent that, for all applicable tax purposes, the Class A Notes and the Class B Notes shall Note will constitute indebtedness and that for all applicable tax purposes, accordingly, the Trust shall Issuer will be treated as sole and exclusive owner of the Pledged PropertyCollateral. Further, each party hereto, hereto and each Noteholder the holder of the Note (or an interest therein) (by receiving and holding a Notethe Note or an interest therein), hereby covenants to every other party hereto and the Noteholders to treat the Class A Notes and the Class B Notes Note as indebtedness for all applicable tax purposes in all tax filings, reports and returns and otherwise, and further covenants that neither it nor any of its Affiliates affiliates will take take, or participate in the taking of, of or permit to be taken, any action that is inconsistent with the treatment of the Class A Notes or of the Class B Notes Note as indebtedness for tax purposespurposes unless otherwise directed by law, rule or regulation or order of any governmental authority. All successors and assigns of the parties hereto shall be bound by the provisions hereof.

Intended Tax Characterization. The parties hereto agree that it is their mutual intent that, for all applicable tax purposes, the Class A Notes and the Class B Notes shall will constitute indebtedness and that for all applicable tax purposes, accordingly, the Trust shall will be treated as sole and exclusive owner of the Pledged Property. Further, each party hereto, hereto and each Noteholder (by receiving and holding a Note), hereby covenants to every other party hereto and the Noteholders to every other Noteholder to treat the Class A Notes and the Class B Notes as indebtedness for all applicable tax purposes in all tax filings, reports and returns and otherwise, and further covenants that neither it nor any of its Affiliates will take take, or participate in the taking of, of or permit to be taken, any action that is inconsistent with the treatment of the Class A Notes or of the Class B Notes as indebtedness for tax purposes. All successors and assigns of the parties hereto shall be bound by the provisions hereof.

Intended Tax Characterization. The parties hereto agree that it is their mutual intent that, for all applicable tax purposes, the Class A Notes and the Class B Notes shall Note will constitute indebtedness and that for all applicable tax purposes, accordingly, the Trust shall Issuer or its owner will be treated as sole and exclusive owner of the Pledged PropertyCollateral. Further, each party hereto, hereto and each Noteholder the holder of the Note (or an interest therein) (by receiving and holding a Notethe Note or an interest therein), hereby covenants to every other party hereto and the Noteholders to treat the Class A Notes and the Class B Notes Note as indebtedness for all applicable tax purposes in all tax filings, reports and returns and otherwise, and further covenants that neither it nor any of its Affiliates will take take, or participate in the taking of, of or permit to be taken, any action that is inconsistent with the treatment of the Class A Notes or of the Class B Notes Note as indebtedness for tax purposespurposes unless otherwise directed by law, rule or regulation or order of any governmental authority. All successors and assigns of the parties hereto shall be bound by the provisions hereof.

Intended Tax Characterization. The parties hereto agree that it is their mutual intent that, for all applicable tax purposes, the Class A Notes and the Class B Subordinate Notes shall will constitute indebtedness and that for all applicable tax purposes, accordingly, the Trust shall will be treated as sole and exclusive owner of the Pledged Property. Further, each party hereto, hereto and each Noteholder (by receiving and holding a Note), hereby covenants to every other party hereto and the Noteholders to every other Noteholder to treat the Class A Notes and the Class B Subordinate Notes as indebtedness for all applicable tax purposes in all tax filings, reports and returns and otherwise, and further covenants that neither it nor any of its Affiliates will take take, or participate in the taking of, of or permit to be taken, any action that is inconsistent with the treatment of the Class A Notes or of the Class B Subordinate Notes as indebtedness for tax purposes. All successors and assigns of the parties hereto shall be bound by the provisions hereof.