Tax Opinion Requirement. Notwithstanding any other part of this Article, no amendment to this Agreement or any Exchange Note Supplement will be effective unless the Borrower delivers an Opinion of Counsel to the Administrative Agent, in form reasonably satisfactory to it, to the effect that such amendment will not cause the Borrower to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes.
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Samples: Collateral Agency Agreement (Mercedes-Benz Auto Lease Trust 2023-A), Collateral Agency Agreement (Mercedes-Benz Auto Lease Trust 2023-A)
Tax Opinion Requirement. Notwithstanding any other part of this Article, no amendment to this Agreement or any Exchange Note Supplement will be effective unless the Borrower delivers an Opinion of Counsel to the Administrative Agent, in form reasonably satisfactory to it, to the effect that such amendment will not (i) cause any Exchange Note to be deemed sold or exchanged for purposes of Section 1001 of the Code or (ii) cause the Borrower to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes.
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Tax Opinion Requirement. Notwithstanding any other part of this ArticleArticle IX, no amendment to this Agreement or any Exchange Note Supplement will be effective unless the Borrower delivers Borrowers deliver an Opinion of Counsel to the Administrative Agent, in form reasonably satisfactory to it, to the effect that such amendment will not (a) cause any Exchange Note to be deemed sold or exchanged for purposes of Section 1001 of the Code or (b) cause any Borrower to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes.
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