Restrictions on Note Acquisitions. (a) Each Certificateholder acknowledges and represents that it is not a member of an “expanded group” (within the meaning of the regulations issued under Section 385 of the Code) that includes a domestic corporation (as determined for U.S. federal income tax purposes) if such domestic corporation, directly or indirectly (through one or more entities that are treated for U.S. federal income tax purposes as partnerships, disregarded entities, or grantor trusts), owns 80% or more of the capital or profits of the Trust.
Appears in 13 contracts
Samples: Trust Agreement (Carvana Auto Receivables Trust 2022-P1), Trust Agreement (Carvana Auto Receivables Trust 2022-P1), Trust Agreement (Carvana Auto Receivables Trust 2021-P4)
Restrictions on Note Acquisitions. (a) Each Certificateholder acknowledges and represents that it is not a member of an “expanded group” (within the meaning of the regulations issued under Section 385 of the Code) that includes a domestic corporation (as determined for U.S. United States federal income tax purposes) if such domestic corporation, directly or indirectly (through one or more entities that are treated for U.S. United States federal income tax purposes as partnerships, disregarded entities, or grantor trusts), owns 80% or more of the capital or profits of the Trust.
Appears in 7 contracts
Samples: Trust Agreement (Carvana Auto Receivables Trust 2021-N4), Trust Agreement (Carvana Auto Receivables Trust 2021-N3), Trust Agreement (Carvana Auto Receivables Trust 2021-N3)