Intended Tax Treatment Notwithstanding anything to the contrary herein or in any other Transaction Document, all parties to this Agreement covenant and agree to treat each Loan under this Agreement as debt (and all Interest as interest) for all federal, state, local and franchise tax purposes and agree not to take any position on any tax return inconsistent with the foregoing.
Tax Treatment If any interest in any Loan Document is transferred to any Transferee which is organized under the laws of any jurisdiction other than the United States or any State thereof, the transferor Lender shall cause such Transferee, concurrently with the effectiveness of such transfer, to comply with the provisions of Section 3.5(iv).
Tax Treatment of Payments Except to the extent otherwise required pursuant to a Determination, Seller, Buyer, the Acquired Companies and their respective Subsidiaries and their respective Affiliates shall treat any and all payments under this Section 6.9, Section 1.2(e), Section 2.1(e), and Article VIII as an adjustment to the consideration for income Tax purposes.