Common use of Seller’s Tax Status Clause in Contracts

Seller’s Tax Status. The Servicer shall not take or cause any action to be taken that could result in the Seller (i) being treated other than as a “disregarded entity” within the meaning of U.S. Treasury Regulation § 301.7701-3 for U.S. federal income tax purposes that is disregarded as separate from a United States person (within the meaning of Section 751200428 16518096 7701(a)(30) of the Code) or (ii) becoming an association taxable as a corporation or a publicly traded partnership taxable as a corporation for U.S. federal income tax purposes.

Seller’s Tax Status. The Servicer shall not take or cause any action to be taken that could result in the Seller (i) being treated other than as (A) a “disregarded entity” within the meaning of U.S. Treasury Regulation § 301.7701-3 for U.S. federal income tax purposes that is disregarded as separate from or (B) a partnership for U.S. federal income tax purposes all of the beneficial owners of which are “United States person (persons” within the meaning of Section 751200428 16518096 7701(a)(30) of the Code) Code or (ii) becoming an association taxable as a corporation or a publicly traded partnership taxable as a corporation for U.S. federal income tax purposes.purposes or (iii) becoming subject to any Tax in any jurisdiction outside the United States or any material state or local tax. 748740795 18564151

Seller’s Tax Status. The Servicer shall not take or cause any action to be taken that could result in the Seller (i) being treated other than as (A) a “disregarded entity” within entity”within the meaning of U.S. Treasury Regulation § 301.7701-3 for U.S. federal income tax purposes that is disregarded as separate from or (B) a partnership for U.S. federal income tax purposes all of the beneficial owners of which are “United States person (persons” within the meaning of Section 751200428 16518096 7701(a)(30) of the Code) Code or (ii) becoming an association taxable as a corporation or a publicly traded partnership taxable as a corporation for U.S. federal income tax purposespurposes or (iii) becoming subject to any Tax in any jurisdiction outside the United States or any material state or local tax.

Seller’s Tax Status. The Servicer shall not take or cause any action to be taken that could result in the Seller (i) being treated other than as (A) a “disregarded entity” within the meaning of U.S. Treasury Regulation § 301.7701-3 for U.S. federal income tax purposes that is disregarded as separate from or (B) a partnership for U.S. federal income tax purposes all of the beneficial owners of which are “United States person (persons” within the meaning of Section 751200428 16518096 7701(a)(30) of the Code) Code or (ii) becoming an association taxable as a corporation or a publicly traded partnership taxable as a corporation for U.S. federal income tax purposespurposes or (iii) becoming subject to any Tax in any jurisdiction outside the United States or any material state or local tax.

Seller’s Tax Status. The Master Servicer shall not take or cause any action to be taken that could result (and shall not fail to take any action the omission of which could result) in the Seller becoming, and shall not permit the Seller to become, (i) being treated other than as a “disregarded entity” within the meaning of U.S. Treasury Regulation § 301.7701-3 that is a wholly-owned subsidiary of a U.S. Person for U.S. federal income tax purposes that is disregarded as separate from a United States person (within the meaning of Section 751200428 16518096 7701(a)(30) of the Code) or purposes, (ii) becoming an association taxable as a corporation or a publicly traded partnership taxable as a corporation for U.S. federal income tax purposes, (iii) subject to any Tax in any jurisdiction outside the United States or (iv) subject to any material amount of Taxes imposed by a state or local taxing authority.