Preparation of IRS Form 8281 by Global Agent. Additionally, the Global Agent shall prepare Form 8281 to be filed with the IRS for each Class M Note issued with OID. For this purpose, the Class M Notes will not be treated as initially issued with OID. In the event that there is a write down (as described in Section 7(b) of this Agreement) with respect to the Class M-1, Class M-2 or Class M-3 Notes, such Class of Notes will be treated as reissued with OID at that time (i.e., all remaining stated interest on such Class of Notes will no longer be qualified stated interest), and the Global Agent shall prepare Form 8281 with respect to such Class M Notes at such time. The Form 8281 must be completed and sent to the Freddie Mac Tax Department by the 15th day after the applicable Class M Notes are treated as reissued with OID.
Preparation of IRS Form 8281 by Global Agent. Additionally, the Global Agent shall prepare Form 8281 to be filed with the IRS for each Original Class M Note issued with OID. For this purpose, the Original Class M Notes will not be treated as initially issued with OID, except if any Class M-2A Notes and Class M-2B Notes are issued on the Closing Date as separate instruments to separate Beneficial Owners, as described in “Certain United States Federal Tax Consequences” in the Offering Circular. In the event that there is a write down (as described in Section 7(b) of this Agreement) with respect to the Class M-1, Class M-2A or Class M-2B Notes, such Class of Notes will be treated as reissued with OID at that time (i.e., all remaining stated interest on such Class of Notes will no longer be qualified stated interest), and the Global Agent shall prepare Form 8281 with respect to such Original Class M Notes at such time. The Form 8281 must be completed and sent to the Freddie Mac Tax Department by the 15th day after the applicable Original Class M Notes are treated as issued or reissued with OID.
Preparation of IRS Form 8281 by Global Agent. Additionally, the Global Agent shall prepare Form 8281 to be filed with the IRS for each Original Class M Note issued with OID. For this purpose, the Class M-2AD and Class M-2BD Notes will be treated as issued with OID and the Class M-2A and Class M-2B Notes will not be treated as initially issued with OID, except if any Class M-2A Notes and Class M-2B Notes are issued on the Closing Date as separate instruments to separate Beneficial Owners, as described in “Certain United States Federal Tax Consequences” in the Offering Circular. For purposes of preparing the Form 8281 for the M-2AD and Class M- 2BD Notes, the Global Agent will create an OID schedule using the same prepayment assumptions used for tax reporting under Section 1272(a)(6) of the Code. In the event that there is a write down (as described in Section 7(b) of this Agreement) with respect to any of the Original Class M Notes, such Class of Notes will be treated as reissued with OID at that time (i.e., all remaining stated interest on such Class of Notes will no longer be qualified stated interest), and the Global Agent shall prepare Form 8281 pursuant to the instructions applicable to contingent payment debt instruments with respect to such Original Class M Notes at such time. The Form 8281 must be completed and sent to the Freddie Mac Tax Department by the 15th day after the applicable Original Class M Notes are treated as issued or reissued with OID.
Preparation of IRS Form 8281 by Global Agent. Additionally, the Global Agent shall prepare Form 8281 to be filed with the IRS for each Original Class M Note issued with OID. For purposes of preparing the Form 8281, the Global Agent will create an OID schedule using the same prepayment assumptions used for tax reporting under Section 1272(a)(6) of the Code. In the event that there is a write down (as described in Section 7(b) of this Agreement) with respect to any Class of Original Class M Notes, such Class of Notes will be treated as reissued with OID at that time (i.e., all remaining stated interest on such Class of Notes will no longer be qualified stated interest), and the Global Agent shall prepare Form 8281 pursuant to the instructions applicable to contingent payment debt instruments with respect to such Original Class M Notes at such time. The Form 8281 must be completed and sent to the Xxxxxxx Mac Tax Department by the 15th day after the applicable Original Class M Notes are treated as issued or reissued with OID.
