Tax Status of the Trust. The Sponsor intends that the Trust shall be treated, for federal, state and local income tax purposes, as a grantor trust, and, notwithstanding anything contained in this Amended and Restated Declaration of Trust to the contrary, neither the Sponsor nor the Trustee, nor any other Person acting for or on behalf of the Trust, shall take any action that is inconsistent with such treatment.
Tax Status of the Trust. It is intended that the trust established hereby be treated as a Grantor Trust of the Corporation under the provisions of Section 671 et seq. of the Code, as the same may be amended from time to time.
Tax Status of the Trust. The Trust 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 VRDP Shares will qualify as tax exempt dividends to the extent designated by the Trust.
Tax Status of the Trust. The assets of the Trust shall be used, subject to the rights of creditors of the Company as specified in paragraph (c) of SECTION 6, to discharge obligations of the Company. Accordingly, the Trust is a "grantor trust" under the provisions of Sections 671 through 677 of the Internal Revenue Code of 1986, as amended. The Company hereby agrees to properly include all items of revenue and expense of the Trust on its Federal income tax return filed with the Internal Revenue Service.
Tax Status of the Trust. The Trust is intended to be treated, and shall be construed, as a trust pursuant to Section 301.7701-4 of the Treasury Regulations and as a grantor trust subject to the provisions of Subchapter J, Subpart E of the Code owned by each Unitholder as grantor in proportion to its respective Ownership Percentage.
Tax Status of the Trust. The Trust is intended to be treated as a ----------------------- trust pursuant to Regulation (S) 301.7701-4 and as a grantor trust subject to the provisions of Subchapter J, Subpart E of the Code owned by each Unitholder as grantor in proportion to the Ownership Percentage of each Unitholder. This Agreement shall be construed in a manner consistent with such intention. Except with respect to the Loans, which for tax purposes shall be treated as loans between Xxxxxxx and each Borrower and a contribution of the loan proceeds by the Borrower to the Trust, any items of income, deduction, credit or loss of the Trust shall be allocated to the Unitholders for federal income tax purposes in accordance with the Ownership Percentages of the Unitholders.
