Common use of Treatment for Tax Purposes Clause in Contracts

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.

Appears in 6 contracts

Samples: Master Repurchase Agreement (Gramercy Capital Corp), Master Repurchase Agreement (Gramercy Capital Corp), Master Repurchase Agreement (Gramercy Capital Corp)

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Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federalfederal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans Assets for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federalfederal, state or local taxing authority.

Appears in 5 contracts

Samples: Master Repurchase and Securities Contract Agreement (Granite Point Mortgage Trust Inc.), Master Repurchase and Securities Contract Agreement (KKR Real Estate Finance Trust Inc.), Master Repurchase and Securities Contract Agreement (KKR Real Estate Finance Trust Inc.)

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans Assets for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.

Appears in 4 contracts

Samples: Bailee Agreement (Colony Credit Real Estate, Inc.), Master Repurchase and Securities Contract Agreement (Colony NorthStar Credit Real Estate, Inc.), Master Repurchase and Securities Contract Agreement (NorthStar Real Estate Income Trust, Inc.)

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax Tax purposes, the Transactions constitute a financing, and that the applicable Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller Sellers and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.

Appears in 3 contracts

Samples: Master Repurchase Agreement (Angel Oak Mortgage, Inc.), Master Repurchase Agreement (Angel Oak Mortgage, Inc.), Master Repurchase Agreement (Angel Oak Mortgage, Inc.)

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax Tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.

Appears in 2 contracts

Samples: Master Repurchase Agreement, Master Repurchase Agreement (Blackstone Mortgage Trust, Inc.)

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax Tax purposes, the Transactions constitute a financing, and that the applicable Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller Xxxxxxx and Buyer Xxxxx agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.

Appears in 2 contracts

Samples: Master Repurchase Agreement (Angel Oak Mortgage, Inc.), Master Repurchase Agreement (Angel Oak Mortgage REIT, Inc.)

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Seller Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.

Appears in 1 contract

Samples: Master Repurchase Agreement (Capital Trust Inc)

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Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federalfederal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans Assets for such purposes. Unless prohibited by applicable law, Seller Seller, Administrative Agent and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federalfederal, state or local taxing authority.

Appears in 1 contract

Samples: Master Repurchase and Securities Contract Agreement (KKR Real Estate Finance Trust Inc.)

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federal, state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans for such purposes. Unless prohibited by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federal, state or local taxing authority.

Appears in 1 contract

Samples: Master Repurchase Agreement (Starwood Property Trust, Inc.)

Treatment for Tax Purposes. It is the intention of the parties that, for U.S. Federalfederal, and relevant state and local income and franchise tax purposes, the Transactions constitute a financing, and that the Seller is, and, so long as no Event of Default shall have occurred and be continuing, will continue to be, treated as the owner of the Purchased Loans Assets for such purposes. Unless prohibited otherwise required by applicable law, Seller and Buyer agree to treat the Transactions as described in the preceding sentence on any and all filings with any U.S. Federalfederal, or relevant state or local taxing authority.

Appears in 1 contract

Samples: Bailee Agreement (TPG RE Finance Trust, Inc.)

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