Tax Treatment; Construction. (a) It is the intention of --------------------------- the parties hereto that the Trust shall be treated as a "grantor trust" for federal income tax purposes and all transactions contemplated by this Trust Agreement will be reported consistent with such treatment. (b) The provisions of this Trust Agreement shall be construed, and the affairs of the Trust shall be conducted, so as to achieve treatment of the Trust as a "grantor trust" for federal income tax purposes.
Appears in 3 contracts
Samples: Declaration and Agreement of Trust (Sdg&e Funding LLC a De Limited Liability Co), Declaration and Agreement of Trust (Pg&e Funding LLC), Declaration and Agreement of Trust (Sce Funding LLC)
Tax Treatment; Construction. (a) It is the intention of --------------------------- the parties hereto that the Trust shall be treated as a "grantor trust" for federal Federal income tax purposes and all transactions contemplated by this Trust Agreement will be reported consistent with such treatment.
(b) The provisions of this Trust Agreement shall be construed, and the affairs of the Trust shall be conducted, so as to achieve treatment of the Trust as a "grantor trust" for federal Federal income tax purposes.
Appears in 3 contracts
Samples: Trust Agreement (Sce Funding LLC), Trust Agreement (Pg&e Funding LLC), Declaration and Agreement of Trust (Sdg&e Funding LLC a De Limited Liability Co)
Tax Treatment; Construction. (a) It is the intention of --------------------------- the parties hereto that the Trust shall be treated as a "grantor trust" for federal income tax purposes and all transactions contemplated by this Trust Agreement will be reported consistent with such treatment.
(b) The provisions of this Trust Agreement shall be construed, and the affairs of the Trust shall be conducted, so as to achieve treatment of the Trust as a "grantor trust" for federal income tax purposes.
Appears in 3 contracts
Samples: Declaration and Agreement of Trust (Sce Funding LLC), Declaration and Agreement of Trust (Pg&e Funding LLC), Declaration and Agreement of Trust (Sdg&e Funding LLC a De Limited Liability Co)
