Common use of Intention of Parties Clause in Contracts

Intention of Parties. The parties hereto intend that 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 27 contracts

Samples: Pass Through Trust Agreement (Sun Country Airlines Holdings, Inc.), Pass Through Trust Agreement, Pass Through Trust Agreement (Sun Country Airlines Holdings, Inc.)

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Intention of Parties. The parties hereto intend that each the 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 Certificateholder, by its acceptance of its Certificate or a beneficial interest therein, agrees to treat the Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 26 contracts

Samples: Pass Through Trust Agreement (Midway Airlines Corp), Pass Through Trust Agreement (Midway Airlines Corp), Pass Through Trust Agreement (Amtran Inc)

Intention of Parties. The parties hereto intend that each the 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 Certificateholder and Investor, by its acceptance of its Certificate or a beneficial interest therein, agrees to treat the Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 9 contracts

Samples: Pass Through Trust Agreement (Jetblue Airways Corp), Pass Through Trust Agreement (Jetblue Airways Corp), Pass Through Trust Agreement (Jetblue Airways Corp)

Intention of Parties. The parties hereto intend that each the Trust be classified for U.S. federal 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 Certificateholder, by its acceptance of its Certificate or a beneficial interest or participation therein, agrees to treat the Trust as a grantor trust for all U.S. Federal, State and local income tax purposes. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 6 contracts

Samples: Trust Agreement (Bond Trust Products LLC), Trust Agreement (Bond Trust Products LLC), Trust Agreement (Bond Trust Products LLC)

Intention of Parties. The parties hereto to this Agreement intend that 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 4 contracts

Samples: Trust Supplement (American Airlines Inc), Pass Through Trust Agreement (Us Airways Inc), Pass Through Trust Agreement (America West Airlines Inc)

Intention of Parties. The parties hereto intend that each the 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 Certificateholder and Investor, by its acceptance of its Certificate or a beneficial interest therein, agrees to treat the Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.. 61

Appears in 3 contracts

Samples: Pass Through Trust Agreement (America West Airlines Inc), Pass Through Trust Agreement (America West Airlines Inc), Pass Through Trust Agreement (America West Airlines Inc)

Intention of Parties. The parties hereto intend that each 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. The powers granted Each Applicable Certificateholder and obligations undertaken pursuant Investor, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to this Agreement shall be so construed so treat the Applicable Trust as to further such intent.a grantor trust for all U.S. federal, state and local income tax

Appears in 3 contracts

Samples: Trust Supplement (Continental Airlines Inc /De/), Trust Supplement (Us Airways Inc), Pass Through Trust Agreement (Continental Airlines Inc /De/)

Intention of Parties. The parties hereto intend that 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. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 3 contracts

Samples: Pass Through Trust Agreement (Atlas Air Inc), Pass Through Trust Agreement (Atlas Air Inc), Pass Through Trust Agreement (Atlas Air Inc)

Intention of Parties. The parties hereto intend that each the 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 Certificateholder, by its acceptance of its Certificate or a beneficial interest or participation therein, agrees to treat the Trust as a grantor trust for all U.S. federal, State and local income tax purposes. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 3 contracts

Samples: Trust Agreement (Incapital Trust Products II LLC), Trust Agreement (Incapital Trust Products LLC), Trust Agreement (Incapital Trust Products LLC)

Intention of Parties. The parties hereto intend that each the 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 Certificateholder and Investor, by its acceptance of its Certificate or a beneficial interest therein, agrees to treat the Trust as a grantor trust for all U.S. federal, state and local income tax purposes. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.63 -58-

Appears in 2 contracts

Samples: Pass Through Trust Agreement (America West Airlines Inc), Pass Through Trust Agreement (America West Airlines Inc)

Intention of Parties. The parties hereto intend that 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 2 contracts

Samples: Pass Through Trust Agreement (United Air Lines Inc), Pass Through Trust Agreement (United Air Lines Inc)

Intention of Parties. The parties hereto intend that 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 powers granted Trustee agrees to hold all assets of each Trust for investment purposes only. Each Certificateholder and obligations undertaken pursuant Investor, by its acceptance of its Certificate or a beneficial interest therein, agrees to this Agreement shall be so construed so treat the Trust as to further such intent.a 71 65

Appears in 1 contract

Samples: Pass Through Trust Agreement (Atlas Air Inc)

Intention of Parties. The parties hereto intend that each the 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 powers granted and obligations undertaken 82 pursuant to this Agreement shall be so construed so as to further such intent.. 83

Appears in 1 contract

Samples: Pass Through Trust Agreement (Continental Airlines Inc /De/)

Intention of Parties. The parties hereto intend that each any Trust created hereunder be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of Chapter 1 of Subtitle A 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.. 63 57

Appears in 1 contract

Samples: Pass Through Trust Agreement (America West Airlines Inc)

Intention of Parties. The parties hereto intend that each the Trust be classified (for U.S. federal Federal income tax purposes purposes) as a grantor trust under Subpart E, Part I of Subchapter J of the Internal Revenue Code of 1986, as amendedCode, and not as a trust or association taxable as a corporation or as a partnership. The powers granted and obligations undertaken pursuant to this Agreement in the Declaration shall be so construed so as to further such intent.

Appears in 1 contract

Samples: Master Terms of Trust (Citicorp North America Inc)

Intention of Parties. The parties hereto to this Agreement intend that 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 1 contract

Samples: Pass Through Trust Agreement (Us Airways Inc)

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Intention of Parties. The parties hereto intend that each the 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 powers granted Each Certificateholder and obligations undertaken pursuant Investor, by its acceptance of its Certificate or a beneficial interest therein, agrees to this Agreement shall be so construed so treat the Trust as to further such intent.a grantor 63 -58-

Appears in 1 contract

Samples: Pass Through Trust Agreement (America West Airlines Inc)

Intention of Parties. The parties hereto intend that each the Trust be classified for U.S. federal 73 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.. 74

Appears in 1 contract

Samples: Pass Through Trust Agreement (Continental Airlines Inc /De/)

Intention of Parties. The parties hereto intend that each the 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.. 83 -76-

Appears in 1 contract

Samples: Pass Through Trust Agreement (Continental Airlines Inc /De/)

Intention of Parties. The parties hereto intend that each any Trust created hereunder be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of Chapter 1 of Subtitle A 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 1 contract

Samples: Pass Through Trust Agreement (America West Airlines Inc)

Intention of Parties. The parties hereto intend that each 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. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.I

Appears in 1 contract

Samples: Pass Through Trust Agreement (Continental Airlines Inc /De/)

Intention of Parties. The parties hereto intend that each the 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 Certificateholder, by its acceptance of its Certificate or a beneficial interest or participation therein, agrees to treat the Trust as a grantor trust for all U.S. Federal, State and local income tax purposes. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.

Appears in 1 contract

Samples: Trust Agreement (Core Bond Products LLC)

Intention of Parties. The parties hereto intend that each the Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of 82 -76- 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.. 83

Appears in 1 contract

Samples: Pass Through Trust Agreement (Continental Airlines Inc /De/)

Intention of Parties. The parties hereto intend that each any Trust created hereunder be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of Chapter 1 of Subtitle A 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 powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.. 66 60

Appears in 1 contract

Samples: Pass Through Trust Agreement (America West Airlines Inc)

Intention of Parties. The parties hereto intend that 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. The powers granted and obligations undertaken pursuant to this Agreement shall be so construed so as to further such intent.. 65

Appears in 1 contract

Samples: Pass Through Trust Agreement (Atlas Air Inc)

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