Common use of Status of the Base Trust Clause in Contracts

Status of the Base Trust. For federal income tax purposes, the Base Trust 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 Trust to take any action necessary to create and maintain the status 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 Base Trust 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 of the Group 6 and Group 8 Classes shall take any action or cause the Trust to take any action necessary to create and maintain the status 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.