Tax Matters Person. The tax matters person with respect to each REMIC (the "Tax Matters Person") shall be the holder of the Tax Matters Person Residual Interest which initially is the Seller. The Tax Matters Person shall at all times hold the Tax Matters Person Residual Interest and shall have the same duties with respect to the Trust as those of a "tax matters partner" under Subchapter C of Chapter 63 of Subtitle F of the Code. Each holder of a Residual Certificate shall be deemed to have agreed, by acceptance thereof, to be bound by this Section 2.11.
Appears in 18 contracts
Samples: Custodial Agreement (Renaissance Mortgage Acceptance Corp), Custodial Agreement (Delta Funding Corp /De/), Custodial Agreement (Delta Funding Home Equity Loan Tr 99-3 Home Eq as Bk Se 99-3)
Tax Matters Person. The tax matters person with respect to each REMIC (the "“Tax Matters Person"”) shall be the holder of the Tax Matters Person Residual Interest which initially is the Seller. The Tax Matters Person shall at all times hold the Tax Matters Person Residual Interest and shall have the same duties with respect to the Trust as those of a "“tax matters partner" ” under Subchapter C of Chapter 63 of Subtitle F of the Code. Each holder of a Residual Certificate shall be deemed to have agreed, by acceptance thereof, to be bound by this Section 2.11.
Appears in 11 contracts
Samples: Pooling and Servicing Agreement (Renaissance Home Equity Loan Trust 2004-2), Custodial Agreement (Home Equity Loan Asset-Backed Certificates Series 2003-2), Pooling and Servicing Agreement (Renaissance Home Equity Loan Trust 2003-4)
Tax Matters Person. The tax matters person with respect to each REMIC (the "Tax Matters Person") shall be the holder of the Tax Matters Person Residual Interest which initially is the Seller. The Tax Matters Person shall at all times hold the Tax Matters Person Residual Interest and shall have the same duties with respect to the Trust as those of a "tax matters partner" under Subchapter C of Chapter 63 of Subtitle F of the Code. Each holder of a Residual Certificate shall be deemed to have agreed, by acceptance thereof, to be bound by this Section 2.11.
Appears in 2 contracts
Samples: Pooling and Servicing Agreement (Delta Funding Corp /De/), Pooling and Servicing Agreement (Delta Funding Corp /De/)
Tax Matters Person. The tax matters person with respect to each REMIC (the "Tax Matters Person") shall be the holder of the Tax Matters Person Residual Interest which initially is the SellerMaster Servicer. The Tax Matters Person shall at all times hold the Tax Matters Person Residual Interest and shall have the same duties with respect to the Trust as those of a "tax matters partner" under Subchapter C of Chapter 63 of Subtitle F of the Code. Each holder of a Residual Certificate shall be deemed to have agreed, by acceptance thereof, to be bound by this Section 2.112.10.
Appears in 1 contract
Samples: Pooling and Servicing Agreement (Mellon Residential Funding Corp)
Tax Matters Person. The tax matters person with respect ------------------ to each the REMIC shall be the Holder of the Tax Matters Person Residual Interest (the "Tax Matters Person") shall be the holder ). The Holder of the Tax Matters Person Residual Interest which initially is the Seller. The Tax Matters Person shall at all times hold the Tax Matters Person Residual Interest and Interests shall have the same duties with respect to the Trust as those of a "tax matters partner" under Subchapter C of Chapter 63 of Subtitle F of the Code. Each holder of a Residual Class R Certificate shall be deemed to have agreed, by acceptance thereof, to be bound by this Section 2.11Section. The Trustee shall hold the Tax Matters Person Residual Interest.
Appears in 1 contract
Samples: Pooling and Servicing Agreement (Morgan Stanley Capital I Inc Home Eq Ln as Bk Cer Ser 1999-2)