Common use of Statement of Intent Clause in Contracts

Statement of Intent. The parties hereto intend that the Applicable Trust be classified for U.S. federal income tax purposes as a grantor trust under Subpart E, Part I of Subchapter J of the Code and not as a trust or association taxable as a corporation or a partnership. Each of the parties hereto and each Applicable Certificateholder, or beneficial owner of an Applicable Certificate, by its acceptance of its Applicable Certificate or a beneficial interest therein, agrees to treat for all U.S. federal, state and local income tax purposes (i) the Applicable Trust as a grantor trust and (ii) Equipment Notes to be issued (or assumed) by an Owner Trust (in the case of a Leased Aircraft) as indebtedness of such Owner Trust, and Equipment Notes issued by the Company (in the case of an Owned Aircraft) as indebtedness of the Company.