Common use of Recharacterized Classes Clause in Contracts

Recharacterized Classes. If one or more Classes of Notes is recharacterized by the United States Internal Revenue Service as an equity interest in the Issuer, and not as indebtedness (a “Recharacterized Class”) and a Recharacterized Class is treated as not owned for U.S. federal income tax purposes by the same entity that owns the Issuer, or if there is more than one equity owner of the Issuer, the parties intend that the Issuer be characterized as a partnership among the Depositor (if it is at that time treated as an equity owner of the Issuer for U.S. federal income tax purposes), any other Trust Certificateholder, and holders of any Recharacterized Class or Classes.