Common use of Tax Treatment, Tax Elections and Other Tax Matters Clause in Contracts

Tax Treatment, Tax Elections and Other Tax Matters. It is the intention of the parties hereto that the Trust shall be classified for U.S. federal income tax purposes as a mere security arrangement or, failing such treatment, as a grantor trust or an entity disregarded from its owner, and not be treated as an association (or publicly-traded partnership) taxable as a corporation. Neither the Depositor, the Trust, nor the Owner Trustee shall cause the Trust to be treated as an association taxable as a corporation for U.S. federal income tax purposes. All provisions of this Agreement shall be construed and the affairs of the Trust shall be conducted to achieve the aforementioned treatment for U.S. federal income tax purposes, and the Noteholders shall agree that all transactions contemplated by this Agreement will be reported on all applicable tax returns consistently with the aforementioned treatment.

Tax Treatment, Tax Elections and Other Tax Matters. It is the intention of the parties hereto that the Trust shall not be classified treated for U.S. federal income tax purposes as a mere security arrangement or, failing such treatment, as a grantor trust or an entity disregarded from its owner, and not be treated as an association (or publicly-traded partnership) taxable as a corporation. Neither the Depositor, the Trust, nor the Owner Trustee shall cause the Trust to be treated as an association taxable as a corporation for U.S. federal income tax purposes. It is the intention of the parties hereto that the Trust shall be treated as a mere security arrangement, or failing such treatment, a grantor trust or a disregarded entity for U.S. federal income tax purposes. All provisions of this Agreement shall be construed and the affairs of the Trust shall be conducted to achieve the aforementioned treatment for U.S. federal income tax purposes, and the Noteholders shall agree that all transactions contemplated by this Agreement will be reported on all applicable tax returns consistently with the aforementioned treatment.

Tax Treatment, Tax Elections and Other Tax Matters. It is the intention of the parties hereto that the Trust shall not be classified treated for U.S. federal income tax purposes as a mere security arrangement or, failing such treatment, as a grantor trust or an entity disregarded from its owner, and not be treated as an association (or publicly-traded partnership) taxable as a corporation. Neither the Depositor, the Trust, Depositor nor the Owner Trustee shall cause the Trust to be treated as an association taxable as a corporation for U.S. federal income tax purposes. It is the intention of the parties hereto that the Trust shall be treated as a grantor trust or a disregarded entity for U.S. federal income tax purposes. All provisions of this Agreement shall be construed and the affairs of the Trust shall be conducted to achieve the aforementioned treatment for U.S. federal income tax purposes, and the Noteholders shall agree that all transactions contemplated by this Agreement will be reported on all applicable tax returns consistently with the aforementioned treatment.