Intention of Parties. The parties hereto intend that the Applicable Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the Agreement shall be so construed so as to further such intent.
Appears in 198 contracts
Samples: Trust Supplement (United Airlines, Inc.), Trust Supplement (United Airlines, Inc.), Trust Supplement (Sun Country Airlines Holdings, Inc.)
Intention of Parties. The parties hereto intend that the Applicable Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the this Agreement shall be so construed so as to further such intent.
Appears in 6 contracts
Samples: Trust Supplement (Continental Airlines Inc /De/), Trust Supplement (Continental Airlines Inc /De/), Trust Supplement (Continental Airlines Inc /De/)
Intention of Parties. The parties hereto intend that the Applicable Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes and shall not take any position inconsistent thereto for any such purposes, unless required by law. The powers granted and obligations undertaken pursuant to the Agreement shall be so construed so as to further such intent.
Appears in 5 contracts
Samples: Trust Supplement (United Air Lines Inc), Trust Supplement (United Air Lines Inc), Trust Supplement (United Air Lines Inc)
Intention of Parties. The parties hereto intend that the Applicable -------------------- Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder and InvestorCertificateholder, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the this Agreement shall be so construed so as to further such intent.
Appears in 2 contracts
Samples: Pass Through Trust Agreement (Midway Airlines Corp), Pass Through Trust Agreement (Midway Airlines Corp)
Intention of Parties. The parties hereto intend that the Applicable each Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. The Trustee agrees to hold all assets of each Trust for investment purposes only. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the this Agreement shall be so construed so as to further such intent.. 72
Appears in 2 contracts
Samples: Pass Through Trust Agreement (Atlas Air Inc), Pass Through Trust Agreement (Atlas Air Inc)
Intention of Parties. The parties hereto intend that the Applicable each Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. The Trustee agrees to hold all assets of each Trust for investment purposes only. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the this Agreement shall be so construed so as to further such intent.. 69
Appears in 2 contracts
Samples: Pass Through Trust Agreement (Atlas Air Inc), Pass Through Trust Agreement (Atlas Air Inc)
Intention of Parties. The parties hereto intend that the Applicable Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the 38 Table of Contents Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the this Agreement shall be so construed so as to further such intent.
Appears in 1 contract
Samples: Pass Through Trust Agreement (Jetblue Airways Corp)
Intention of Parties. The parties hereto intend that the Applicable Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the Agreement shall be so construed so as to further such intent. ARTICLE IX THE CERTIFICATES Section 9.
Appears in 1 contract
Samples: Trust Supplement (Us Airways Inc)
Intention of Parties. The parties hereto intend that the Applicable each Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amended, and not as a trust or association taxable as a corporation or as a partnership. The Trustee agrees to hold all assets of each Trust for investment purposes only. Each Applicable Certificateholder and Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat the Applicable Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to the this Agreement shall be so construed so as to further such intent.. 70
Appears in 1 contract
