Common use of Retention By Depositors Clause in Contracts

Retention By Depositors. Any Note retained or acquired by the Depositors at any time on or after the Closing Date may be issued, transferred or exchanged by the Depositors only upon the delivery to the Indenture Trustee of an Opinion of Counsel dated as of the date of such issuance, transfer or exchange, as the case may be, to the effect that such issuance, transfer or exchange will not cause (i) any other security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code or (ii) the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes.

Retention By Depositors. Any Note retained or acquired by the Depositors at any time on or after the Closing Date may be issued, transferred or exchanged by the Depositors only upon on the delivery to the Indenture Trustee of an Opinion of Counsel dated as of the date of such the issuance, transfer or exchange, as the case may be, to the effect that such the issuance, transfer or exchange will not cause (i) any other security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code or (ii) the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes.