Common use of Signature on Returns; Tax Matter Partner Clause in Contracts

Signature on Returns; Tax Matter Partner. (a) The Administrator on behalf of the Trust shall sign on behalf of the Trust the tax returns of the Trust, unless applicable law requires a Certificateholder to sign such documents, in which case such documents shall be signed by the Administrator, pursuant to the power-of-attorney granted thereto pursuant to Section 2.04. (b) For any period during which the beneficial ownership interests of the Trust are held by more than one Person (and all such owners are not treated as the same Person for federal income tax purposes), if the Depositor (of an Affiliate of Depositor) is a Certificateholder, the Depositor (or an affiliate of Depositor) shall be designated the “tax matters partner” of the Trust pursuant to Section 6231(a)(7)(A) of the Code and applicable Treasury Regulations to the extent allowed by the Code. If the Depositor (or an affiliate of Depositor) cannot be so designated under law, the Certificateholder holding Certificates evidencing the largest portion of the Original Certificate Balance shall be designated the “tax matters partner” of the Trust pursuant to Section 6231(a)(7)(A) of the Code and applicable Treasury Regulations, but hereby delegates its powers and duties as such to the Administrator pursuant to the power-of-attorney granted thereto pursuant to Section 2.04.