Common use of Status of the Base Trust Clause in Contracts

Status of the Base Trust. For federal income tax purposes, the portion of the Base Trust consisting of (i) the Assigned Rights and all proceeds thereof and (ii) the Net WAC Carryover Account and all amounts held therein or credited thereto will be treated as a grantor trust under Subpart E, Part I of Subchapter J of the Code and not as an association taxable as a corporation. The Trustee and the Certificateholders shall take any action or cause the Base Trust to take any action necessary to create and maintain the status of such portion of the Base Trust as a grantor trust for federal income tax purposes and shall assist each other as necessary to create or maintain such status.

Status of the Base Trust. For federal income tax purposes, the portion of the Base Trust consisting of (i) the Assigned Rights Group 2 and Group 3 Loans and all proceeds thereof and (ii) the Net WAC Carryover Base Trust Account and all amounts held therein or credited thereto will be treated as a grantor trust under Subpart E, Part I of Subchapter J of the Code and not as an association taxable as a corporation. The Trustee and the Certificateholders shall take any action or cause the Base Trust to take any action necessary to create and maintain the status of such portion of the Base Trust as a grantor trust for federal income tax purposes and shall assist each other as necessary to create or maintain such status.

Status of the Base Trust. For federal income tax purposes, the portion of the Base Trust consisting of (i) the Assigned Rights Group 2, Group 3 and Group 4 Loans and all proceeds thereof and (ii) the Net WAC Carryover Base Trust Account and all amounts held therein or credited thereto will be treated as a grantor trust under Subpart E, Part I of Subchapter J of the Code and not as an association taxable as a corporation. The Trustee and the Certificateholders shall take any action or cause the Base Trust to take any action necessary to create and maintain the status of such portion of the Base Trust as a grantor trust for federal income tax purposes and shall assist each other as necessary to create or maintain such status.

Status of the Base Trust. For federal income tax purposes, the portion of the Base Trust consisting of (i) the Assigned Rights Group 1 Loans and all proceeds thereof and (ii) the Net WAC Carryover Base Trust Account and all amounts held therein or credited thereto will be treated as a grantor trust under Subpart E, Part I of Subchapter J of the Code and not as an association taxable as a corporation. The Trustee and the Certificateholders shall take any action or cause the Base Trust to take any action necessary to create and maintain the status of such portion of the Base Trust as a grantor trust for federal income tax purposes and shall assist each other as necessary to create or maintain such status.

Status of the Base Trust. For federal income tax purposes, the portion of the Base Trust consisting of (i) the Assigned Rights Group 2 and Group 4 Loans and all proceeds thereof and (ii) the Net WAC Carryover Base Trust Account and all amounts held therein or credited thereto will be treated as a grantor trust under Subpart E, Part I of Subchapter J of the Code and not as an association taxable as a corporation. The Trustee and the Certificateholders shall take any action or cause the Base Trust to take any action necessary to create and maintain the status of such portion of the Base Trust as a grantor trust for federal income tax purposes and shall assist each other as necessary to create or maintain such status.