Common use of Tax Reporting and Characterization Clause in Contracts

Tax Reporting and Characterization. The Member agrees that for U.S. federal, State and local income and franchise tax purposes it will (i) treat its interest in the Company as a direct ownership interest in the Member Property and all other assets of the Company and the Securitization Entities (including, in each case, all amounts received with respect thereto and all proceeds and recoveries thereof), (ii) treat any Securities outstanding (the gross proceeds of such Securities less the principal payments on such Securities) as its indebtedness, (iii) treat each Securitization Entity as a security device and (iv) not treat the Company or this Agreement as creating a co-ownership of any assets or as creating a separate entity (such as a partnership). The Member will not take any action that is inconsistent with this Section.

Tax Reporting and Characterization. The Member agrees that for U.S. federal, State and local income and franchise tax purposes it will (i) treat its interest in the Company as a direct ownership interest in the Member Property and all other assets of the Company and the Securitization Entities (including, in each case, all amounts received with respect thereto and all proceeds and recoveries thereof), (ii) treat any Securities outstanding (the gross proceeds of such Securities less the principal payments on such Securities) as its indebtedness, (iii) treat each Securitization Entity as a security device and (iv) not treat the Company or this Agreement as creating a co-ownership of any assets or as creating a separate entity (such as a partnership). The Member will not take any action that is inconsistent with this Section.

Tax Reporting and Characterization. The Member agrees that for U.S. federal, State state and local income and franchise tax purposes it will (ia) treat its interest in the Company as a direct ownership interest in the Member Property and all other assets of the Company and the Securitization Entities (including, in each case, all amounts received with respect thereto and all proceeds and recoveries thereof), (iib) treat any Securities outstanding (the gross proceeds of such Securities less the principal payments on such Securities) as and its indebtedness, (iiic) treat each Securitization Entity as a security device device, and (ivd) not treat the Company or this Agreement as creating a co-ownership of any assets or as creating a separate entity (such as a partnership). The Member will not take any action that is inconsistent with this SectionSection 2.6.