Owner for Federal Tax Purposes. It is hereby agreed among Lessee, the Owner Participant and the Owner Trustee that for Federal income tax purposes the Owner Participant will be the owner of the Aircraft to be delivered under the Lease and Lessee will be the lessee thereof, and each party hereto agrees to characterize the Lease as a lease for Federal income tax purposes.
Owner for Federal Tax Purposes. It is hereby agreed between the Owner Participant and the Lessee (but the Lessee makes no representation to such effect) that it is the intent of the parties for Federal, state, local and foreign income tax purposes that the Owner Participant will be treated as the owner of the Aircraft and the Lessee will be treated as the lessee of the Aircraft.
Owner for Federal Tax Purposes. It is the intent of the parties to this Agreement that the Lease be treated as a true lease, the Owner Participant be treated as the owner of the Aircraft to be delivered under the Lease, and Lessee be treated as the lessee thereof for Federal income tax purposes.
Owner for Federal Tax Purposes. 83 Section 17.02. Collateral Account...................................... 83 Section 17.03. Counterparts............................................ 84 Section 17.04. No Oral Modifications................................... 84 Section 17.05. Captions................................................ 84 Section 17.06. Successors and Assigns.................................. 84 Section 17.07. Concerning the Owner Trustee, the Pass Through Trustee and the Indenture Trustee.................... 85 Section 17.08. Severability............................................ 85 Section 17.09. Public Release of Information........................... 85 Section 17.10. Certain Limitations on Reorganization................... 86 Section 17.11. GOVERNING LAW........................................... 86 Section 17.12. Section 1110 Compliance................................. 86 ARTICLE 18 CONFIDENTIALITY Section 18.01. Confidentiality......................................... 87
Owner for Federal Tax Purposes. 89 Section 17.02. Collateral Account...................................... 89 Section 17.03. Counterparts............................................ 90 Section 17.04. No Oral Modifications................................... 90 Section 17.05. Captions................................................ 91 Section 17.06. Successors and Assigns.................................. 91 Section 17.07. Concerning the Owner Trustee, Indenture Trustee and the Pass Through Trustee.................................... 91 Section 17.08. Severability............................................ 92 Section 17.09. Public Release of Information........................... 92 Section 17.10. Certain Limitations on Reorganization................... 92 Section 17.11. GOVERNING LAW........................................... 93 Section 17.12. Section 1110 Compliance................................. 93 Section 17.13. Reliance of Liquidity Providers......................... 93 ARTICLE 18 CONFIDENTIALITY Section 18.01. Confidentiality......................................... 93 SCHEDULE I Certificate Information SCHEDULE II Definitions SCHEDULE III Permitted Country List SCHEDULE IV Debt Portion EXHIBIT A(1)(a)(i) Opinion of Lessee's Counsel (Certificate Closing Date) EXHIBIT A(1)(a)(ii) Opinion of Lessee's Counsel (Delivery Date) EXHIBIT A(1)(b)(i) Opinion of Lessee's Special Counsel (Certificate Closing Date) EXHIBIT A(1)(b)(ii) Opinion of Lessee's Special Counsel (Delivery Date) EXHIBIT A(2)(a) Opinion of Owner Participant's and Owner Participant Guarantor's Special Counsel EXHIBIT A(2)(b) Opinion of Owner Participant's and Owner Participant Guarantor's Counsel EXHIBIT A(3) Opinion of Indenture Trustee's Special Counsel EXHIBIT A(4)(a)(i) Opinion of Owner Trustee's Special Counsel (Certificate Closing Date) EXHIBIT A(4)(a)(ii) Opinion of Owner Trustee's Special Counsel (Delivery Date) EXHIBIT A(5) Opinion of Pass Through Trustee's and Subordination Agent's Special Counsel EXHIBIT A(6)(a) Opinion of Liquidity Provider's Counsel EXHIBIT A(6)(b) Opinion of Liquidity Provider's Special Counsel EXHIBIT A(7) Opinion of Engine Manufacturer's Counsel EXHIBIT A(8) Opinion of Manufacturer's and AVSA's Counsel EXHIBIT A(9) Opinion of Special Aviation Counsel EXHIBIT B Form of Lease Agreement EXHIBIT C Form of Indenture EXHIBIT D Form of Trust Agreement EXHIBIT E Form of Purchase Agreement Assignment, Consent and Agreement, AVSA Consent and Agreement EXHIBIT F Form of Engine Warranty Assignment and...
Owner for Federal Tax Purposes. It is hereby agreed between Lessee and Lessor that, for Federal income tax purposes (i) the Lease is, and will be consistently treated as, a finance lease rather than a true lease; (ii) Lessee will be the owner of the Equipment to be delivered under this Lease; (iii) Lessee will not claim any rental deduction for amounts paid to Lessor under the Lease; (iv) Lessor will not claim any cost recovery or depreciation deductions with respect to the Equipment delivered under this Lease; (v) neither Lessor nor Lessee will at any time take any action, directly or in directly, or file any returns or other documents inconsistent with the foregoing; and (vi) Lessor and Lessee will file such returns, take such actions and execute such documents as may be reasonable and necessary to facilitate accomplishment of the intent expressed in subparagraphs (i) through (iv) of this Section 9(d).
Owner for Federal Tax Purposes. It is hereby agreed among Sublessor and Sublessee that for Federal income tax purposes the Owner will be the owner of the Aircraft and Sublessee will be the sublessee thereof, and each party hereto agrees to characterize this Sublease as a lease for Federal income tax purposes.
Owner for Federal Tax Purposes. It is hereby agreed among Lessor and Lessee that for Federal income tax purposes the Owner will be the owner of the Engine and Lessee will be the lessee thereof, and each party hereto agrees to characterize this Lease as a lease for Federal income tax purposes.
Owner for Federal Tax Purposes. It is hereby agreed between Lessees and the Owner Participants that for Federal income tax purposes the Owner Trustee will be the owner of the Equipment to be delivered under the Lease and Lessees will be the lessees thereof.
Owner for Federal Tax Purposes. It is hereby agreed among ------------------------------- Lessee, the Owner Participant and the Owner Trustee that for U.S. federal income tax purposes the Owner Participant will be the owner of the Aircraft to be delivered under the Lease and Lessee will be the lessee thereof, and each party hereto agrees to characterize the Lease as a lease for U.S. Federal tax purposes. It is understood and agreed among Lessee, the Owner Participant and the Owner Trustee that for U.S. federal income tax purposes, the Lease Agreement shall constitute a substantial modification of the Original Lease, within the meaning of Treasury Regulations section 1.467-1(f)(5)(ii).
