Tax Status of Trust. It is intended that the Trust established hereby shall be treated as a grantor trust of the Savings Bank under the provisions of Section 671 et seq. of the Internal Revenue Code of 1986, as amended, as the same may be amended from time to time.
Tax Status of 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 Trust. It is intended that the trust established hereby be treated as a grantor trust of the Association under the provisions of Section 671, et seq., of the Internal Revenue Code of 1986, as amended (26 U.S.C. Section 671 et seq.).
Tax Status of Trust. For federal income tax purposes, each Trust formed under this Trust Agreement will be treated as a fixed investment trust under the Internal Revenue Code and applicable Treasury Regulations, and not as an association taxable as a corporation. The Trust Documents will be interpreted so as not to provide any “power to vary the investment” (within the meaning of the applicable Treasury Regulations) of any Trust formed under this Trust Agreement. The Trustee will take any action or cause the Trust to take any action necessary to create and maintain the status of each Trust as a fixed investment trust for federal income tax purposes; provided that if any such action would require the consent of Holders under Article X, the Trustee will not effect that action without the requisite consent of Holders.
Tax Status of Trust. The trust is intended to be a grantor trust, of which the Company is the grantor, within the meaning of subpart E, part 1, subchapter J, chapter 1, subtitle A of the Code, and shall be construed accordingly. Until advised otherwise, the Trustee and the Company may presume that the Trust is so characterized for Federal income tax purposes and the Trustee shall make all filings of tax returns on that presumption.
Tax Status of Trust. It is intended that the Company, as grantor hereunder, be treated as the owner of the entire trust and the trust assets under Section 671, et seq. of the Code. Until advised otherwise, the Trustee may presume that the Trust is so characterized for federal income tax purposes and shall make ail filings of tax returns on that presumption.
Tax Status of Trust. The Company intends by this Trust Agreement to create a trust forming a part of the Plan which shall meet the requirements for qualification under section 401(a) of the Code and which shall be exempt from tax pursuant to section 501(a) of the Code.
Tax Status of Trust. The Sponsor intends by this Trust Agreement to create a trust forming a part of the Plan which shall meet the requirements for qualification under section 401(a) of the Code and which shall be exempt from tax pursuant to section 501(a) of the Code.
Tax Status of Trust. The Trust, the Depositor, the ------------------- Property Trustee, the Administrative Trustee, the Delaware Trustee, and the Holders have entered into this Trust Agreement, and the Trust Securities will be issued, with the intention that (i) the Trust will be classified as a grantor trust under subpart E, part I of subchapter J of the Code and not as an association taxable as a corporation or a publicly traded partnership taxable as a corporation for purposes of federal income tax law, and (ii) the Holders will be treated as the owners of a pro rata undivided interest in each asset of the Trust. The Trust, the Depositor, the Property Trustee, the Administrative Trustee, the Delaware Trustee, and each Holder agree to treat and to take no action inconsistent with the treatment of the Trust Securities (or beneficial interest therein) as interests in a grantor trust for purposes of federal, state and local income and franchise taxes. The Trust, the Depositor, the Property Trustee, the Administrative Trustee and the Delaware Trustee agree to take no action with respect to the Trust or any interest therein that would cause the Trust to be treated as an association or publicly traded partnership taxable as a corporation for purposes of federal income tax law. Each Holder, by acquisition of a Trust Security (or a beneficial interest therein), agrees to be bound by the provisions of this Section 2.10. Notwithstanding any other provision in this Trust Agreement to the contrary, the Trustees shall have no power to vary the investment of the Holders within the meaning of Treasury Department Regulation (S) 301.7701-4(c) or to engage in business in its capacity as a Trustee hereunder unless, the Trustees shall have received an Opinion of Counsel that such activity shall not cause the Trust to be an association or a publicly traded partnership taxable as a corporation for federal income tax purposes. The provisions of this Trust Agreement shall be construed in light of the foregoing intended tax treatment.
Tax Status of Trust. The Trust herein created is designated as constituting a part of a plan intended to be taxed as a grantor trust under Subchapter J of the Internal Revenue Code, with the Company as grantor.
