Common use of Tax Treatment of the Class P Certificates Clause in Contracts

Tax Treatment of the Class P Certificates. It is the intent of the parties hereto that the segregated pool of assets consisting of any collections payable to Class P Certificates constitutes, for federal income tax purposes, a grantor trust as described in Subpart E of Part I of Subchapter J of the Code and Treasury Regulation §301.7701-4(c)(2). The Trustee shall prepare, sign and file all of the tax returns in respect of such grantor trust. The expenses of preparing and filing such returns shall be borne by the Trustee without any right of reimbursement therefor. The Trustee shall comply with each such requirement by filing Form 1041.

Tax Treatment of the Class P Certificates. It is the intent of the parties hereto that the segregated pool of assets consisting of any collections in respect of the Class P Distributable Amount payable to Class P Certificates constitutes, for federal income tax purposes, a grantor trust as described in Subpart E of Part I of Subchapter J of the Code and Treasury Regulation §301.7701-4(c)(2). The Trustee shall prepare, sign and file all of the tax returns in respect of such grantor trust. The expenses of preparing and filing such returns shall be borne by the Trustee without any right of reimbursement therefor. The Trustee shall comply with each such requirement by filing Form 1041.