FEDERAL TAX ASPECTS definition

FEDERAL TAX ASPECTS. The trust, exclusive of the Pre-funding account and the Capitalized Interest account, will consist of two segregated asset pools, (the "Upper-Tier REMIC" and the "Lower-Tier REMIC"). Each class of the Offered Certificates will be designated as a "regular interest" in the Upper-Tier REMIC.
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FEDERAL TAX ASPECTS. It is anticipated that the Certificates will be treated as REMIC regular interests for tax purposes ERISA CONSIDERATIONS: The Senior Certificates are expected to be ERISA eligible. The Subordinate Certificates will NOT be ERISA eligible.
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FEDERAL TAX ASPECTS. The trust will be an Owner Trust. No election will be made to treat the Trust Estate or any portion thereof as a REMIC for federal income tax purposes. The Notes will be treated as non-recourse debt obligations of the trust.
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Examples of FEDERAL TAX ASPECTS in a sentence

  • FEDERAL TAX ASPECTS: The trust, exclusive of the Pre-funding account and the Capitalized Interest account, will consist of two segregated asset pools, (the "Upper-Tier REMIC" and the "Lower-Tier REMIC").

  • By: ----------------------------------------- ******************************************************************************** FEDERAL TAX ASPECTS The following discussion is a general description of expected federal income tax results under current law.

  • By_________________________________ FEDERAL TAX ASPECTS The Plan is a non-qualified deferred compensation plan under the provisions of the Internal Revenue Code.


More Definitions of FEDERAL TAX ASPECTS

FEDERAL TAX ASPECTS. No election will be made to treat the Trust Estate or any portion thereof as a REMIC for federal income tax purposes. The Notes will be treated as non-recourse obligations of the Issuer and the Issuer will not be characterized as an association (or a publicly traded partnership) taxable as a corporation. Investors are advised to consult their tax advisors and to review the Prospectus and Prospectus Supplement.
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FEDERAL TAX ASPECTS. It is anticipated that the Certificates will be treated as REMIC regular interests for tax purposes.
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FEDERAL TAX ASPECTS. The Trust will consist of two segregated asset pools, (the "Upper-Tier REMIC" and the "Lower-Tier REMIC"). Each class of the Offered Certificates will be designated as a "regular interest" in the Upper-Tier REMIC. AUGUST 25, 1998 DEUTSCHE BANK SECURITIES [/] -------------------------------------------------------------------------------- IMC HOME EQUITY LOAN TRUST 1998-5 -------------------------------------------------------------------------------- DESCRIPTION OF SECURITIES (CONTINUED) ERISA CONSIDERATION: All of the Senior Certificates are expected to be ERISA eligible. The Subordinate Certificates will NOT be ERISA eligible.
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FEDERAL TAX ASPECTS. The Trust will consist of two segregated asset pools, (the "Upper-Tier REMIC" and the "Lower-Tier REMIC"). Each class of the Offered Certificates will be designated as a "regular interest" in the Upper-Tier REMIC. This Structural Term Sheet, Collateral Term Sheet, or Computational Materials, as appropriate (the "material"), was prepared solely by the Underwriter(s), is privileged and confidential, is intended for use by the addressee only, and may not be provided to any third party other than the addressee's legal, tax, financial and/or accounting advisors for the purposes of evaluating such information. Prospective investors are advised to read carefully, and should rely solely on, the final prospectus and prospectus supplement (the "Final Prospectus") related to the securities (the "Securities") in making their investment decisions. This material does not include all relevant information relating to the Securities described herein, particularly with respect to the risk and special considerations associated with an investment in the Securities. All information contained herein is preliminary and it is anticipated that such information will change. Any information contained herein will be more fully described in, and will be fully superseded by the preliminary prospectus supplement, if applicable, and the Final Prospectus. Although the information contained in the material is based on sources the Underwriter(s) believe(s) to be reliable, the Underwriter(s) make(s) no representation or warranty that such information is accurate or complete. Such information should not be viewed as projections, forecasts, predictions, or opinions with respect to value. Prior to making any investment decision, a prospective investor shall receive and fully review the Final Prospectus. NOTHING HEREIN SHOULD BE CONSIDERED AN OFFER TO SELL OR SOLICITATION OF AN OFFER TO BUY ANY SECURITIES. The Underwriter(s) may hold long or short positions in or buy and sell Securities or related securities or perform for or solicit investment banking services from, any company mentioned herein. Pg. 5 September 21, 1998 Deutsche Bank Securities[/] -------------------------------------------------------------------------------- IMC HOME EQUITY LOAN TRUST 1998-6 -------------------------------------------------------------------------------- DESCRIPTION OF SECURITIES (Continued)
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FEDERAL TAX ASPECTS. The Trust will be established as one or more REMICs for federal income tax purposes. ERISACONSIDERATIONS: The Class A Certificates and the Class A-IO Certificates may be purchased by a pension or other employee benefit plan subject to the Employee Retirement Income Security Act of 1974 or Section 4975 of the Internal Revenue Code of 1986, or by an entity investing the assets of an employee benefit plan so long as certain conditions are met.
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Related to FEDERAL TAX ASPECTS

  • Federal Tax means any Tax imposed under Subtitle A of the Code.

  • Income Tax Return means any Tax Return relating to Income Taxes.

  • Intended Tax Treatment has the meaning set forth in the Recitals.

  • Federal Tax Certificate means the Issuer's Federal Tax Certificate dated as of the Issue Date, as the same may be amended or supplemented in accordance with the provisions thereof.

  • Income Tax Act means the Income Tax Act, 1962 (Act No. 58 of 1962);

  • criminal tax matters means tax matters involving intentional conduct whether before or after the entry into force of this Agreement which is liable to prosecution under the criminal laws of the requesting Party;

  • Swiss Federal Tax Administration means the tax authorities referred to in article 34 of the Swiss Withholding Tax Act.

  • Income Tax Returns means all Tax Returns relating to Income Taxes.

  • Tax means any present or future tax, levy, impost, duty, charge, assessment or fee of any nature (including interest, penalties and additions thereto) that is imposed by any government or other taxing authority in respect of any payment under this Agreement other than a stamp, registration, documentation or similar tax.

  • council tax benefit means council tax benefit under Part 7 of the SSCBA; “couple” has the meaning given by paragraph 4;

  • Assumed State and Local Tax Rate means the tax rate equal to the sum of the products of (x) the Corporation’s income tax apportionment factor for each state and local jurisdiction in which the Corporation files income or franchise tax returns for the relevant Taxable Year and (y) the highest corporate income and franchise tax rate in effect for such Taxable Year for each such state and local jurisdiction in which the Corporation files income tax returns for each relevant Taxable Year.

  • Tax Treatment [One or more elections will be made to treat the assets of the Trust Fund as a REMIC.] [The Trust Fund will be treated as a "grantor trust" for federal income tax purposes.]

  • Applicable Tax State means, as of any date, (i) any State in which the Owner Trustee maintains the Corporate Trust Office, (ii) any State in which the Owner Trustee maintains its principal executive offices and (iii) any State in which the Servicer regularly conducts servicing and collection activities (other than purely ministerial activities) with respect to a material portion of the Receivables.

  • Special Tax Requirement means that amount required in any Fiscal Year to: (i) pay debt service on all Outstanding Bonds; (ii) pay periodic costs on the Bonds, including but not limited to, credit enhancement and rebate payments on the Bonds; (iii) pay Administrative Expenses; (iv) pay any amounts required to establish or replenish any reserve funds for all Outstanding Bonds; (v) pay directly for the acquisition or construction of facilities authorized to be financed by IA No. 2 to the extent that inclusion of such amount does not increase the Special Tax levy on Undeveloped Property; and (vi) pay for reasonably anticipated Special Tax delinquencies based on the historical delinquency rate for IA No. 2 as determined by the CFD Administrator; less (vii) a credit for funds available to reduce the annual Special Tax levy, as determined by the CFD Administrator pursuant to the Indenture.

  • After-relieved Federal tax means any amount of Federal excise tax or duty, except social security or other employment taxes, that would otherwise have been payable on the transactions or property covered by this contract, but which the Contractor is not required to pay or bear, or for which the Contractor obtains a refund or drawback, as the result of legislative, judicial, or administrative action taking effect after the contract date.

  • Applicable Tax Law means any Applicable Law relating to Taxes, including regulations and other official pronouncements of any Governmental Entity or political subdivision of such jurisdiction charged with interpreting such Applicable Law.

  • Structure means a walled and roofed building, a manufactured home, or a gas, liquid, or liquefied gas storage tank that is principally above ground.

  • Assumed Tax Liability means, with respect to any Member, an amount equal to the excess of (i) the product of (A) the Distribution Tax Rate multiplied by (B) the estimated or actual cumulative taxable income or gain of the Company, as determined for federal income tax purposes, allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, less prior losses of the Company allocated to such Member (or its predecessor) for full or partial Fiscal Years commencing on or after January 1, 2021, in each case, as determined by the Manager and to the extent such prior losses are available to reduce such income over (ii) the cumulative Tax Distributions made to such Member after the closing date of the IPO pursuant to Sections 4.01(b)(i), 4.01(b)(ii) and 4.01(b)(iii) and, if applicable with respect to such Fiscal Year, pursuant to Section 4.1(a) of the Previous LLC Agreement; provided that, in the case of the Corporation, such Assumed Tax Liability (x) shall be computed without regard to any increases to the tax basis of the Company’s property pursuant to Sections 734(b) or 743(b) of the Code and (y) to the extent permitted under the Credit Agreements and applicable Law, shall in no event be less than an amount that will enable the Corporation to meet both its tax obligations and its obligations pursuant to the Tax Receivable Agreement for the relevant Taxable Year; provided further that, in the case of each Member, and for the avoidance of doubt, such Assumed Tax Liability shall take into account any Code Section 704(c) allocations (including “reverse” 704(c) allocations) to the Member.

  • Integrated Goods and Services Tax Act means the Integrated Goods and Services Tax Act, 2017;

  • PAYEE TAX REPRESENTATIONS Each representation specified in the Schedule as being made by it for the purpose of this Section 3(f) is accurate and true.

  • Regulatory Requirements means all applicable laws, rules, regulations, orders, requirements, guidelines, interpretations, directives and requests (whether or not having the force of law) from and of, and plans, memoranda and agreements with, any Regulatory Authority.

  • Hypothetical Tax Liability means, with respect to any Taxable Year, the liability for Taxes of the Corporation (or the Partnerships, but only with respect to Taxes imposed on the Partnerships and allocable to the Corporation) using the same methods, elections, conventions and similar practices used on the relevant Corporation Return but using the Non-Stepped Up Tax Basis instead of the tax basis reflecting the Basis Adjustments of the Adjusted Assets and excluding any deduction attributable to Imputed Interest.

  • Agreement combined tax rate means the sum of the tax rates:

  • After-imposed Federal tax means any new or increased Federal excise tax or duty, or tax that was exempted or excluded on the contract date but whose exemption was later revoked or reduced during the contract period, on the transactions or property covered by this contract that the Contractor is required to pay or bear as the result of legislative, judicial, or administrative action taking effect after the contract date. It does not include social security tax or other employment taxes.

  • Payroll Tax Executive Order means the Presidential Memorandum on Deferring Payroll Tax Obligations in Light of the Ongoing COVID-19 Disaster, as issued on August 8, 2020 and including any administrative or other guidance published with respect thereto by any Governmental Authority (including IRS Notice 2020-65).

  • Consolidated federal income tax return means a consolidated return filed for federal income tax purposes pursuant to section 1501 of the Internal Revenue Code.