Common use of Tax Matters Partner and Partnership Representative Clause in Contracts

Tax Matters Partner and Partnership Representative. If the Issuer is not treated as an entity disregarded as separate from the Majority Equity Holder for U.S. federal income tax purposes, the Majority Equity Holder will (i) prepare and sign, on behalf of the Issuer, the tax returns of the Issuer and (ii) be designated the “tax matters partner” of the Issuer under Section 6231(a)(7)(A) of the Code. If the Issuer is classified as a partnership for U.S. federal income tax purposes as of January 1, 2018, or if later, the date that the BBA Partnership Audit Rules are first applicable to the Issuer, the Majority Equity Holder is designated as the partnership representative of the Issuer under Section 6223(a) of the Code to the extent allowed under the law.

Appears in 20 contracts

Samples: Trust Agreement (Ford Credit Auto Owner Trust 2017-C), Trust Agreement (Ford Credit Auto Owner Trust 2017-C), Trust Agreement (Ford Credit Auto Lease Trust 2017-B)

AutoNDA by SimpleDocs
Draft better contracts in just 5 minutes Get the weekly Law Insider newsletter packed with expert videos, webinars, ebooks, and more!