Intention of Parties to Establish Trust. This Trust Agreement is intended to create a 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 Trust Agreement may be amended to comply with such federal income tax laws, which amendments may apply retroactively.
Appears in 2 contracts
Samples: Common Equity Trust Agreement (Enron Corp/Or/), Preferred Equity Trust Agreement (Enron Corp/Or/)
Intention of Parties to Establish Trust. This Trust 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 therewith and, if necessary, this Trust Agreement may be amended to comply with such federal income tax laws, which amendments may apply retroactively. This Agreement is not intended to create and shall not be interpreted as creating a corporation, association, partnership or joint venture of any kind for federal income taxation or any other purpose.
Appears in 2 contracts
Samples: Liquidating Trust Agreement (THCG Inc), Liquidating Trust Agreement (THCG Inc)
Intention of Parties to Establish Trust. This Trust Agreement is intended to create a liquidating trust for U.S. federal income tax purposes and(including, to the extent provided by lawwithout limitation, for purposes of IRS Revenue Procedure 94-45, 1994-2 C.B. 684), and shall be governed and construed in all respects as consistently with such a trust and intent. Notwithstanding anything to the contrary contained herein, any ambiguity herein in this Agreement shall be construed consistent herewith consistently with the immediately preceding sentence, and, if necessary, this Trust Agreement may be amended to comply with such federal income tax laws, which amendments may apply retroactively.
Appears in 1 contract
Samples: Custodial Trust Agreement