Debt-For-Tax Opinion definition

Debt-For-Tax Opinion means an Opinion of Counsel, of nationally recognized tax counsel, delivered to the Depositor and the Indenture Trustee stating that the Notes specified therein will be debt for United States federal income tax purposes.
Sample 1Sample 2Sample 3
Debt-For-Tax Opinion means an Opinion of Counsel, of nationally recognized tax counsel, delivered to the Depositor and the Indenture Trustee stating that the Notes specified therein will be debt for United States federal income tax purposes.
Sample 1Sample 2Sample 3

Examples of Debt-For-Tax Opinion in a sentence

  • No transfer of Non-Investment Grade Notes will be permitted to the extent that such transfer would cause the number of direct or indirect holders of an interest in the Non-Investment Grade Notes and the Residual Interest to exceed a number equal to 95 Persons unless a Debt-For-Tax Opinion has been delivered.

  • No transfer of Non-Investment Grade Notes (or any interest therein) will be permitted to the extent that such transfer would cause the number of direct or indirect holders of an interest in the Non-Investment Grade Notes and the Residual Interest to exceed a number equal to 95 Persons unless a Debt-For-Tax Opinion has been delivered.

Related to Debt-For-Tax Opinion

  • Unqualified Tax Opinion means a reasoned “will” opinion, without qualifications, of a nationally recognized law firm to the effect that a transaction will not affect the Tax-Free Status of the Transactions. For purposes of this definition, an opinion is reasoned if it describes the reasons for the conclusions and includes the facts, assumptions, and supporting legal analysis.

  • U.S. Tax Person means a Person that is a “United States person” as defined in Section 7701(a)(30) of the Code, generally including: