Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, (ii) cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;
Appears in 52 contracts
Samples: Indenture (Ford Credit Auto Owner Trust 2024-D), Indenture (Ford Credit Auto Receivables Two LLC), Indenture (Ford Credit Auto Owner Trust 2024-C)
Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, (ii) cause the Issuer or a Titling Company to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;
Appears in 32 contracts
Samples: Indenture (Ford Credit Auto Lease Trust 2024-B), Indenture (Ford Credit Auto Lease Trust 2024-B), Indenture (Ford Credit Auto Lease Trust 2024-A)
Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not cause (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, Code or (ii) cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;
Appears in 25 contracts
Samples: Omnibus Amendment (Verizon Owner Trust 2020-A), Transfer and Servicing Agreement (Verizon Owner Trust 2020-B), Omnibus Amendment (Verizon Owner Trust 2020-C)
Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the mergerconsolidation, consolidation merger or transfer will not cause (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, Code or (ii) cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;
Appears in 5 contracts
Samples: Indenture (Ford Credit Auto Receivables Two LLC), Indenture (Ford Credit Auto Receivables Two LLC), Indenture (Ford Credit Auto Receivables Two LLC)
Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not cause (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, Code or (ii) cause the Issuer or a Titling Company to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;
Appears in 5 contracts
Samples: Indenture (Ford Credit Auto Lease Two LLC), Indenture (Ford Credit Auto Lease Two LLC), Indenture (CAB East LLC)