Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company within the meaning of Section 851(a) of the Code and the dividends made with respect to the VMTP Shares will qualify as “exempt interest dividends” to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 14 contracts
Samples: VMTP Purchase Agreement (Bank of America Corp /De/), VMTP Purchase Agreement (Bank of America Corp /De/), Registration Rights Agreement (Bank of America Corp /De/)
Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company "regulated investment company" within the meaning of Section 851(a) 851 of the Code and the dividends made with respect to the VMTP RVMTP Shares will qualify as “"exempt interest dividends” " to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 12 contracts
Samples: RVMTP Purchase Agreement (Bank of America Corp /De/), RVMTP Purchase Agreement (Bank of America Corp /De/), RVMTP Purchase Agreement (Bank of America Corp /De/)
Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company "regulated investment company" within the meaning of Section 851(a) of the Code and the dividends made with respect to the VMTP Shares will qualify as “"exempt interest dividends” " to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 7 contracts
Samples: VMTP Purchase Agreement (Bank of America Corp /De/), Purchase Agreement (Bank of America Corp /De/), VMTP Purchase Agreement (Bank of America Corp /De/)
Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company “regulated investment company” within the meaning of Section 851(a) of the Code and the dividends made with respect to the VMTP Shares will qualify as “exempt interest dividends” to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 5 contracts
Samples: VMTP Purchase Agreement (Bank of America Corp /De/), VMTP Purchase Agreement (Bank of America Corp /De/), VMTP Purchase Agreement (Bank of America Corp /De/)
Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company "regulated investment company" within the meaning of Section 851(a) of the Code and the dividends made with respect to the 2019 VMTP Shares will qualify as “"exempt interest dividends” " to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 2 contracts
Samples: Purchase Agreement (Bank of America Corp /De/), Purchase Agreement (Bank of America Corp /De/)
Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company within the meaning of Section 851(a) of the Code and the dividends made with respect to the New VMTP Shares will qualify as “exempt interest dividends” to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 1 contract
Samples: VMTP Purchase Agreement (Bank of America Corp /De/)
Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company “regulated investment company” within the meaning of Section 851(a) 851 of the Code and the dividends made with respect to the VMTP RVMTP Shares will qualify as “exempt interest dividends” to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 1 contract
Samples: RVMTP Purchase Agreement (Bank of America Corp /De/)
Tax Status of the Issuer. The Issuer will qualify as a Regulated Investment Company "regulated investment company" within the meaning of Section 851(a) 851 of the Code and the dividends made with respect to the VMTP Shares will qualify as “"exempt interest dividends” " to the extent they are reported as such by the Issuer and permitted by Section 852(b)(5)(A) of the Code.
Appears in 1 contract