Issuing Entity Tax Opinion definition

Issuing Entity Tax Opinion means, with respect to any Action, an Opinion of Counsel to the effect that, for United States federal income tax purposes, (a) such Action will not cause any Outstanding Series, Class or Tranche of Notes that were characterized as debt at the time of their issuance to be characterized as other than debt, (b) such Action will not cause the Issuing Entity to be treated as an association (or publicly traded partnership) taxable as a corporation and (c) such Action will not cause or constitute an event in which gain or loss would be recognized by any Holder of any such Notes.
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Issuing Entity Tax Opinion means, with respect to any Action, an Opinion of Counsel to the effect that, for United States federal income tax purposes, (a) such Action will not cause any Outstanding Series, Class or Tranche of Notes that were characterized as debt at the time of their issuance to be characterized as other than debt,
Sample 1

Examples of Issuing Entity Tax Opinion in a sentence

  • Any purported transfer by the Beneficiary of all or any part of its right, title and interest in and to the Beneficial Interest to any Person will be effective only upon the issuance of a Master Trust Tax Opinion, if applicable, and an Issuing Entity Tax Opinion (each as defined in the Indenture), which will not be an expense of the Owner Trustee and the satisfaction of any additional conditions to the designation of an Additional Transferor provided in Section 2.07 of the Transfer and Servicing Agreement.

  • Transfers of the Beneficial Interest may be made between the Transferor and any other Person who is an Affiliate of the Transferor (a “Permitted Affiliate Transferee”) only upon delivery to the Master Trust Trustee and the Owner Trustee of a Master Trust Tax Opinion, if applicable, and an Issuing Entity Tax Opinion, respectively, with respect to such transfer.

Related to Issuing Entity Tax Opinion

  • Tax Administrator means the individual charged with direct responsibility for administration of an income tax levied by a municipal corporation in accordance with this chapter, and also includes the following:

  • Assumed Tax Rate means the highest effective marginal combined U.S. federal, state and local income tax rate for a Fiscal Year prescribed for an individual or corporate resident in New York, New York (taking into account (a) the nondeductiblity of expenses subject to the limitation described in Section 67(a) of the Code and (b) the character (e.g., long-term or short-term capital gain or ordinary or exempt income) of the applicable income, but not taking into account the deductibility of state and local income taxes for U.S. federal income tax purposes). For the avoidance of doubt, the Assumed Tax Rate will be the same for all Partners.

  • Zoning Administrator means the administrator of these rules who is appointed by the natural resources commission.