Intention of Parties. The parties hereto intend that the Class B Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the Code, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, a Class B Certificate, by its acceptance of its Class B Certificate or a beneficial interest therein, agrees to treat the Class B Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 19 contracts
Samples: Through Trust Agreement (American Airlines, Inc.), Trust Supplement (Jetblue Airways Corp), Through Trust Agreement (Jetblue Airways Corp)
Intention of Parties. The parties hereto intend that the Class B A Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the Code, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, a Class B A Certificate, by its acceptance of its Class B A Certificate or a beneficial interest therein, agrees to treat the Class B A Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B A Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 18 contracts
Samples: Through Trust Agreement (American Airlines, Inc.), 2020 1a (Delta Air Lines, Inc.), Through Trust Agreement (American Airlines Inc)
Intention of Parties. The parties hereto intend that the Class B Applicable Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, 1E of Chapter 1 1J of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder of, and each Person acquiring a beneficial interest in, a Class B of an Applicable Certificate, by its acceptance of its Class B Applicable Certificate or a beneficial interest therein, agrees to treat the Class B Applicable Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B Applicable Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 10 contracts
Samples: Participation Agreement Indenture and Security Agreement (American Airlines Inc), Trust Agreement (American Airlines Inc), Participation Agreement Refunding Agreement Lease Agreement (American Airlines Inc)
Intention of Parties. The parties hereto intend that the Class B AA Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the Code, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, a Class B AA Certificate, by its acceptance of its Class B AA Certificate or a beneficial interest therein, agrees to treat the Class B AA Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B AA Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 9 contracts
Samples: Trust Agreement (Delta Air Lines, Inc.), Trust Supplement (Spirit Airlines, Inc.), Through Trust Agreement (American Airlines Inc)
Intention of Parties. The parties hereto intend that the Class B C Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the Code, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, a Class B C Certificate, by its acceptance of its Class B C Certificate or a beneficial interest therein, agrees to treat the Class B C Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B C Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 4 contracts
Samples: Intercreditor Agreement (Spirit Airlines, Inc.), Trust Supplement (Spirit Airlines, Inc.), Trust Agreement (American Airlines Inc)
Intention of Parties. The parties hereto intend that the Class B C Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, of a Class B C Certificate, by its acceptance of its Class B C Certificate or a beneficial interest therein, agrees to treat the Class B C Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B C Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 2 contracts
Samples: Through Trust Agreement (Delta Air Lines Inc /De/), Trust Agreement (Delta Air Lines Inc /De/)
Intention of Parties. The parties hereto intend that the Class B Applicable Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, 1E of Chapter 1 1J of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder of, and each Person acquiring a beneficial interest in, a Class B of an Applicable Certificate, by its acceptance of its Class B Applicable Certificate or a beneficial interest therein, agrees to treat the Class B Applicable Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B Applicable Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).. 20
Appears in 2 contracts
Samples: Participation Agreement Refunding Agreement Lease Agreement (American Airlines Inc), Participation Agreement Refunding Agreement Lease Agreement (American Airlines Inc)
Intention of Parties. The parties hereto intend that the Class B G-1 Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, of a Class B G-1 Certificate, by its acceptance of its Class B G-1 Certificate or a beneficial interest therein, agrees to treat the Class B G-1 Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B G-1 Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
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Intention of Parties. The parties hereto intend that the Class B Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, of a Class B Certificate, by its acceptance of its Class B Certificate or a beneficial interest therein, agrees to treat the Class B Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 1 contract
Intention of Parties. The parties hereto intend that the Class B G Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, of a Class B G Certificate, by its acceptance of its Class B G Certificate or a beneficial interest therein, agrees to treat the Class B G Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B G Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
Appears in 1 contract
Samples: Delta Air Lines Inc /De/
Intention of Parties. The parties hereto intend that the Class B G-2 Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, of a Class B G-2 Certificate, by its acceptance of its Class B G-2 Certificate or a beneficial interest therein, agrees to treat the Class B G-2 Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B G-2 Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
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Intention of Parties. The parties hereto intend that the Class B A Trust be classified for United States federal income tax purposes as a grantor trust under Subpart E, Part I, Subchapter J, Chapter 1 of Subtitle A of the CodeInternal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Certificateholder of, and each Person acquiring a beneficial interest in, of a Class B A Certificate, by its acceptance of its Class B A Certificate or a beneficial interest therein, agrees to treat the Class B A Trust as a grantor trust for all United States federal, state and local income tax purposes. The Trustee shall not be authorized or empowered to do anything that would cause the Class B A Trust to fail to qualify as a grantor trust for such tax purposes (including as subject to this restriction, acquiring any Aircraft by bidding the Equipment Notes relating thereto or otherwise, or taking any action with respect to any such Aircraft once acquired).
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