Tax Characterization. Each party to this Agreement (a) acknowledges that it is the intent of the parties to this Agreement that, for accounting purposes and for all Federal, State and local income and franchise tax purposes, the Loans will be treated as evidence of indebtedness issued by the Borrower, (b) agrees to treat the Loans for all such purposes as indebtedness and (c) agrees that the provisions of the Transaction Documents shall be construed to further these intentions.
Appears in 7 contracts
Samples: Warehouse Credit Agreement (LendingClub Corp), Warehouse Credit Agreement (LendingClub Corp), Assignment and Assumption Agreement (LendingClub Corp)
Tax Characterization. Each party to this Agreement (a) acknowledges that it is the intent of the parties to this Agreement that, for accounting purposes and for all Federal, State state and local income and franchise tax purposes, the Loans Note will be treated as evidence of indebtedness issued by the BorrowerIssuer, (b) agrees to treat the Loans Note for all such purposes as indebtedness and (c) agrees that the provisions of the Transaction Basic Documents shall be construed to further these intentions.
Appears in 3 contracts
Samples: Note Purchase Agreement (Gehl Co), Note Purchase Agreement (Consumer Portfolio Services Inc), Note Purchase Agreement (Consumer Portfolio Services Inc)
Tax Characterization. Each party to this Agreement (a) acknowledges that it is the intent of the parties to this Agreement that, for accounting purposes and for all Federal, State state and local income and franchise tax purposes, the Loans will be treated as evidence of indebtedness issued by the Borrower, (b) agrees to treat the Loans for all such purposes as indebtedness and (c) agrees that the provisions of the Transaction Loan Documents shall be construed to further these intentions.
Appears in 2 contracts
Samples: Credit Agreement (Consumer Portfolio Services Inc), Credit Agreement (Consumer Portfolio Services Inc)
Tax Characterization. Each party to this Agreement (a) acknowledges that it is the intent of the parties to this Agreement that, for accounting purposes and for all Federal, State state and local income and franchise tax purposes, the Loans each Purchaser’s share of a Series A Advance will be treated as a separate evidence of indebtedness issued by the Borrowerindebtedness, (b) agrees to treat the Loans each Series A Advance for all such purposes as indebtedness and (c) agrees that the provisions of the Transaction Documents shall be construed to further these intentions.
Appears in 1 contract
Samples: Note Purchase Agreement (OneMain Financial Holdings, Inc.)
Tax Characterization. (a) Each party to this Agreement (ai) acknowledges that it is the intent of the parties to this Agreement that, for accounting purposes and for all Federalfederal, State state and local income and franchise tax purposes, the Loans Advances will be treated as evidence of indebtedness issued by the Borrowerindebtedness, (bii) agrees to treat the Loans Advances for all such purposes as indebtedness and (ciii) agrees that the provisions of the Transaction Related Documents shall be construed to further these intentions.
Appears in 1 contract
Samples: Advance Funding Agreement (European Wax Center, Inc.)
Tax Characterization. Each party to this Agreement (a) acknowledges that it is the intent of the parties to this Agreement that, for accounting purposes and for all Federalfederal, State and local income and franchise tax purposes, the Loans will be treated as evidence of indebtedness issued by the Borrower, (b) agrees to treat the Loans for all such purposes as indebtedness and (c) agrees that the provisions of the Transaction Documents shall be construed to further these intentions.
Appears in 1 contract
Tax Characterization. Each party to this Agreement (a) acknowledges that it is the intent of the parties to this Agreement that, for accounting purposes and for all Federalfederal, State and local income and franchise tax purposes, the Loans will be treated as evidence of indebtedness issued by the Borrower, (b) agrees to treat the Loans for all such purposes as indebtedness and (c) agrees that the provisions of the Transaction Documents shall be construed to further these intentions.as
Appears in 1 contract
