Tax Characterization. Notwithstanding the provisions of Section 2.01 hereof, the Depositor and Owner Trustee agree that pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii), the Trust is to be disregarded as a separate entity from the Depositor for federal income tax purposes.
Appears in 7 contracts
Sources: Pooling and Servicing Agreement (NCT Funding Co LLC), Pooling and Servicing Agreement (Cit Equipment Collateral 2000-2), Pooling and Servicing Agreement (Cit Equipment Collateral 2003-Vt1)
Tax Characterization. Notwithstanding the provisions of Section 2.01 and Section 2.04 hereof, the Depositor and Owner Trustee agree that pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii), the Trust is to be disregarded as a separate entity from the Depositor for federal income tax purposes.
Appears in 6 contracts
Sources: Pooling and Servicing Agreement (Goldman Sachs Asset Backed Securities Corp), Pooling and Servicing Agreement (Asset Backed Securities Corp), Pooling and Servicing Agreement (NCT Funding Co LLC)
Tax Characterization. Notwithstanding the provisions of Section 2.01 hereofof the Pooling and Servicing Agreement, the Depositor and the Owner Trustee agree that pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii), the Trust is to be disregarded as a separate entity from the Depositor for federal income tax purposes.. [signature page follows]
Appears in 4 contracts
Sources: Trust Agreement (CIT Equipment Collateral 2004-Ef1), Trust Agreement (NCT Funding Co LLC), Trust Agreement (Cit Equipment Collateral 2003-Ef1)
Tax Characterization. Notwithstanding the provisions of Section 2.01 hereofof the Pooling Agreement, the Depositor and the Owner Trustee agree that pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii), the Trust is to be disregarded as a separate entity from the Depositor for federal income tax purposes.
Appears in 3 contracts
Sources: Trust Agreement (Cit Equipment Collateral 2006-Vt2), Trust Agreement (CIT Equipment Collateral 2008-Vt1), Trust Agreement (Cit Funding Co, LLC)
Tax Characterization. Notwithstanding the provisions of Section 2.01 and Section 2.04 hereof, the Trust Depositor and Owner Trustee agree that pursuant to Treasury Regulations Section 301.7701-3(b)(1)(ii), the Trust is to be disregarded as a separate entity from the Trust Depositor for federal and State of Illinois income tax purposes.
Appears in 2 contracts
Sources: Sale and Servicing Agreement (Heller Funding Corp Ii), Sale and Servicing Agreement (Heller Funding Corp)