Tax Treatment of the Notes. By purchasing the Class M Notes, Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxxx Mac for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat the Class M Notes in some other manner pursuant to a final determination by the Internal Revenue Service or by a court of competent jurisdiction (each a “Final Tax Determination”). By purchasing the Class B Notes, Holders agree to treat such Class B Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Offering Circular, unless such Holders are required to treat the Class B Notes in some other manner pursuant to a Final Tax Determination. Holders and Beneficial Owners, as applicable, further agree (a) to prepare their U.S. federal income tax returns on the basis that (i) the Class M Notes will be treated as indebtedness of Xxxxxxx Mac and/or (ii) the Class B Notes will be treated as (1) a deemed loan and (2) an on-market swap, and (b) to report items of income, deduction, gain or loss with respect to the Original Notes in a manner consistent with the information reported to them pursuant to Section 3.01(d), unless otherwise required pursuant to a previously-selected method for tax accounting for contingent notional principal contracts or a Final Tax Determination.
Tax Treatment of the Notes. (a) By purchasing Class 2M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 2B-1 Notes in some other manner pursuant to a Final Tax Determination.
Tax Treatment of the Notes. By purchasing the Original Notes, Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxxx Mac for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat the Original Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each a “Final Tax Determination”). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that the Original Notes will be treated as indebtedness of Xxxxxxx Mac and to report items of income, deduction, gain or loss with respect to the Original Notes in a manner consistent with the information reported to them pursuant to Section 3.01(d), unless otherwise required pursuant to a Final Tax Determination.
Tax Treatment of the Notes. By purchasing the Original Notes, Holders and Beneficial Owners agree to treat such Notes as indebtedness of Freddie Mac for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat the Original Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each a “Final Tax Determination”). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that the Original Notes will be treated as indebtedness of Freddie Mac and to report items of income, deduction, gain or loss with respect to the Original Notes in a manner consistent with the information reported to them pursuant to Section 3.01(d), unless otherwise required pursuant to a Final Tax Determination.
Tax Treatment of the Notes. Each of the Depositor and the Servicer agree to treat the Notes as indebtedness for U.S. federal income, State and local income and franchise tax purposes.
Tax Treatment of the Notes. By purchasing the Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat the Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that the Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to the Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination.
Tax Treatment of the Notes. The Issuers have entered into this Indenture, and each Class of Notes will be issued, with the intention that, for purposes of any federal, state and local income or franchise tax and any other taxes imposed on or measured by income, such Notes will qualify as indebtedness (unless otherwise provided in the applicable Series Supplement) upon their issuance for federal income tax purposes. The Issuers, by entering into this Indenture, each Noteholder, by acceptance of its Note, and each Note Owner, by purchasing or otherwise acquiring an Ownership Interest in a Note, agree to treat the Notes and such Ownership Interests for purposes of any federal, state and local income or franchise tax and any other taxes imposed on or measured by income, as indebtedness (unless otherwise provided in the applicable Series Supplement) upon their issuance for federal income tax purposes.
Tax Treatment of the Notes. The Guarantor agrees to treat the Notes as indebtedness of PartnerRe U.S. Corporation for United States federal, state and local tax purposes.
Tax Treatment of the Notes. By purchasing the Notes, Holders agree to treat the Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Offering Circular, unless such Holders are required to treat the Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each a “Final Tax Determination”). Holders and Beneficial Owners, as applicable, further agree (a) to prepare their U.S. federal income tax returns on the basis that the Notes will be treated as (1) a deemed loan and (2) an on-market swap, and (b) to report items of income, deduction, gain or loss with respect to the Notes in a manner consistent with the information reported to them pursuant to Section 3.01(d), unless otherwise required pursuant to a previously-selected method for tax accounting for contingent notional principal contracts or a Final Tax Determination.
Tax Treatment of the Notes. By purchasing the Original Class M Notes (including any Original Class M Notes sold by virtue of a sale of related MAC Notes), Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxxx Mac for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat the Original Class M Notes in some other manner pursuant to a final determination by the Internal Revenue Service or by a court of competent jurisdiction (each a “Final Tax Determination”). By purchasing the Class B-1D, Class B-1I, Class B-1, or Class B-2D Notes, Holders agree to treat such Class B-1D, Class B-1I, Class B-1, or Class B-2D Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Offering Circular, unless such Holders are required to treat the Class B-1D, Class B-1I, Class B-1, or Class B-2D Notes in some other manner pursuant to a Final Tax Determination. Holders and Beneficial Owners, as applicable, further agree (a) to prepare their U.S. federal income tax returns on the basis that (i) the Original Class M Notes (including any Original Class M Notes sold by virtue of a sale of related MAC Notes) will be treated as indebtedness of Xxxxxxx Mac and/or (ii) the Class B-1D, Class B-1I, Class B-1, or Class B-2D Notes will be treated as (1) a deemed loan and (2) an on-market swap, and (b) to report items of income, deduction, gain or loss with respect to the Original Notes in a manner consistent with the information reported to them pursuant to Section 3.01(d), unless otherwise required pursuant to a previously-selected method for tax accounting for contingent notional principal contracts or a Final Tax Determination.
