Tax Characterization of the CIA Certificates. It is the -------------------------------------------- intention of the parties hereto that the CIA Certificates be treated for tax purposes as indebtedness. In the event that the CIA Certificates are not so treated, it is the intention of the parties that the CIA Certificates be treated as an interest in a partnership that owns the Receivables. In the event that the CIA Certificates are treated as an interest in a partnership, it is the intention of the parties that interest payable on the CIA Certificates be treated as guaranteed payment and, if for any reason it is not so treated, that the holders of the CIA Certificates be specially allocated gross interest income equal to the interest accrued during each Interest Period on the CIA Certificates.
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Samples: Pooling and Servicing Agreement (First Usa Inc), Pooling and Servicing Agreement (First Usa Credit Card Master Trust), Pooling and Servicing Agreement (First Usa Inc)
Tax Characterization of the CIA Certificates. It is the -------------------------------------------- intention of the parties hereto that the CIA Certificates be treated for tax purposes as indebtedness. In the event that the CIA Certificates are not so treated, it is the intention of the parties that the CIA Certificates be treated as an interest in a partnership that owns the Receivables. In the event that the CIA Certificates are treated as an interest in a partnership, it is the intention of the parties that interest payable on the CIA Certificates be treated as guaranteed payment payments and, if for any reason it is not so treated, that the holders of beneficial interests in the CIA Certificates be specially allocated gross interest income equal to the interest accrued during each Interest Period on the CIA Certificates.
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