Common use of Treatment of Trust Clause in Contracts

Treatment of Trust. The Administrator agrees, for U.S. federal, state and local income and franchise tax purposes, to treat (i) the Trust as a grantor trust, (ii) the Trust's Notes as an ownership interest in such grantor trust and (iii) the Funding Agreements as debt of Protective Life. The Administrator will not take any action that it knows could cause the Trust not to be treated as a grantor trust for U.S. federal income tax purposes.

Treatment of Trust. The Administrator agrees, for U.S. federal, state and local income and franchise tax purposes, to treat (i) the Trust as a grantor trust, (ii) the Trust's ’s Notes as an ownership interest in such grantor trust and (iii) the Funding Agreements as debt of Protective Life. The Administrator will not take any action that it knows could cause the Trust not to be treated as a grantor trust for U.S. federal income tax purposes.