Intention of Parties to Establish Grantor Trust. This Agreement is intended to create a grantor trust for United States federal income tax purposes and, to the extent provided by law, shall be governed and construed in all respects as a grantor trust.
Intention of Parties to Establish Grantor Trust. This Agreement is intended to create a grantor trust for United States federal income tax purposes and, to the extent provided by law, shall be governed and construed in all respects as a grantor trust. For all federal income tax purposes, the Beneficiaries of the Trust will be treated as grantors and owners thereof and it is intended that the Trust be classified as a liquidating Trust under 26 C.F.R.§ 301.7701–4 and that the Trust is owned by the Beneficiaries. Accordingly, for federal income tax purposes, it is intended that the Beneficiaries be treated as if they had received a distribution of an undivided interest in the Assets and then contributed such interests to the Trust. Accordingly, the Trust shall, in an expeditious but orderly manner, and pursuant to the terms of this Agreement, Settlement Agreement, the Plan and the Confirmation Order, liquidate and convert to Cash the Assets, make timely distributions to the Beneficiaries pursuant to the Settlement Agreement and the Plan, and not unduly prolong the Trust’s duration unnecessarily. The Trust shall not be deemed a successor in interest of the Settlor for any purpose other than as specifically set forth herein, the Settlement Agreement, the Plan and Confirmation Order.
Intention of Parties to Establish Grantor Trust. This Agreement is not intended to create and shall not be interpreted as creating an association, partnership, corporation or joint venture of any kind. It is intended to create a trust to be governed and construed in all respects as a grantor trust. The U.S. Trust Beneficiaries will be treated as the grantors of the Transferred Assets to the Liquidating Trust and deemed owners, through the U.S. Distribution Trust, of an undivided proportionate share in the Liquidating Trust Assets.
Intention of Parties to Establish Grantor Trust. This UCT Agreement is intended to create a grantor trust with respect to the Beneficiaries for United States federal income tax purposes, and to the extent provided by law, shall be governed and construed in all respects as a grantor trust with respect to the Beneficiaries.
Intention of Parties to Establish Grantor Trust. This Agreement is not intended to create and shall not be interpreted as creating an association, partnership, corporation or joint venture of any kind. It is intended to create a trust to be governed and construed in all respects as a grantor trust. The Canada Trust Beneficiaries will be treated as the grantors of the Transferred Assets to the Liquidating Trust and deemed indirect owners through this Canada Distribution Trust of an undivided proportionate interest in the Liquidating Trust Assets.
Intention of Parties to Establish Grantor Trust. This Agreement is intended to create a “liquidating trust” for federal income tax purposes and, to the extent provided by law, shall be governed and construed in all respects as such a trust and any ambiguity herein shall be construed consistent herewith and, if necessary, this Agreement may be amended to comply with such federal income tax laws, which amendments may apply retroactively.
Intention of Parties to Establish Grantor Trust. This Creditors’ Trust Agreement is intended to create for federal income tax purposes a "grantor trust" that satisfies the requirements of IRC sections 671 et seq. and, to the extent provided by law, shall be governed and construed in all respects as a grantor trust with the Beneficiaries as its grantors, with the exception of the DOF. Notwithstanding anything to the contrary contained herein, any ambiguity herein shall be construed consistent herewith and, if necessary, this Creditors’ Trust Agreement may be amended to comply with such federal income tax laws, which amendments may apply retroactively.
