Nondisqualification Opinion. An Opinion of Counsel, prepared at the Trust’s expense and payable from the Collection Account, that a contemplated action will not cause (i) either the Lower-Tier REMIC or the Upper-Tier REMIC to fail to qualify as a REMIC or (ii) a “prohibited transaction” or “prohibited contributions” tax to be imposed on either the Lower-Tier REMIC or the Upper-Tier REMIC at any time that any Certificates are outstanding.

Nondisqualification Opinion means a written Opinion of Counsel to the effect that a contemplated action (i) will neither cause any REMIC Pool to fail to qualify as a REMIC at any time that any Certificates are outstanding nor cause a “prohibited transaction,” “prohibited contribution” or any other tax (other than a tax on “net income from foreclosure property” permitted to be incurred under this Agreement) to be imposed on any REMIC Pool or the Trust and (ii) will not cause the Grantor Trust to fail to qualify as a grantor trust.

Nondisqualification Opinion means a written Opinion of Counsel to the effect that a contemplated action will neither cause any REMIC Pool to fail to qualify as a REMIC at any time that any Certificates are outstanding nor cause a "prohibited transaction," "prohibited contribution" or any other tax (other than a tax on "net income from foreclosure property" permitted to be incurred under this Agreement) to be imposed on any REMIC Pool or the Trust.

Examples of Nondisqualification Opinion in a sentence

The Special Servicer may conclusively rely on any advice of counsel rendered in a Nondisqualification Opinion.
Prior to entering into any amendment without the consent of Holders pursuant to this paragraph, the Trustee may require an Opinion of Counsel, addressed to the parties to this Agreement, to the effect that such amendment is permitted under this paragraph and a Nondisqualification Opinion.
The Trustee may request, at its option, to receive a Nondisqualification Opinion and an Opinion of Counsel that any amendment pursuant to this Section 14.3(c) is permitted by this Agreement at the expense of the party requesting the amendment.
The Trustee may request, at its option, to receive a Nondisqualification Opinion and an Opinion of Counsel that any amendment pursuant to this Section 13.3(c) is permitted by this Agreement at the expense of the party requesting the amendment.
The applicable Special Servicer may conclusively rely on any advice of counsel rendered in a Nondisqualification Opinion.

More Definitions of Nondisqualification Opinion

Nondisqualification Opinion. An Opinion of Counsel, prepared at the Trust’s expense and payable from the Collection Account, to the effect that a contemplated action will not result in an Adverse REMIC Event.

Nondisqualification Opinion. An Independent Opinion of Counsel addressed to the Trustee that a contemplated action will neither cause the Trust REMIC to fail to qualify as a REMIC at any time the Class A Certificates are outstanding nor cause an unindemnified "prohibited transaction" or a "prohibited contribution" tax to be imposed on the Trust REMIC.

Nondisqualification Opinion means an opinion of tax counsel, which shall be independent outside counsel, to the effect that a contemplated action would not materially adversely affect the Federal income tax status as a REMIC, trust or other vehicle of any REMIC, trust or other vehicle in which the Loan may be included at the time such opinion is required.

Nondisqualification Opinion means an Opinion of Counsel to the effect that a contemplated action or non-action, as the case may be, will not result in an Adverse REMIC Event or an Adverse Grantor Trust Event.

Nondisqualification Opinion. An Opinion of Counsel, prepared at the Trust Fund’s expense and payable from the Collection Account, to the effect that a contemplated action will not cause (i) either the Lower-Tier REMIC or the Upper-Tier REMIC to fail to qualify as a REMIC at any time that any Certificates or RR Interest are outstanding or (ii) a “prohibited transaction” or “prohibited contributions” tax to be imposed on either the Lower-Tier REMIC or the Upper-Tier REMIC at any time that any Certificates or RR Interest are outstanding.

Nondisqualification Opinion means a written opinion of Independent nationally recognized outside tax counsel addressed to the Trustee, reasonably acceptable in form and substance to the Trustee, that a contemplated action will neither cause (i) any REMIC Pool to fail to qualify as a REMIC at any time that any Certificates are outstanding nor (ii) a gain on the disposition of a Qualified Mortgage which would be subject to the 100% tax on "prohibited transactions," imposed by Section 860F of the Code, nor (iii) any REMIC Pool to be subject to any tax under the REMIC Provisions, except for any tax on net income from foreclosure property as provided for herein.

Nondisqualification Opinion means a written Opinion of Counsel to the effect that a contemplated action (i) will neither cause any REMIC Pool to fail to qualify as a REMIC at any time that any Certificates are outstanding nor cause a "prohibited transaction," "prohibited contribution" or any other tax (other than a tax on "net income from foreclosure property" permitted to be incurred under this Agreement) to be imposed on any REMIC Pool or the Trust and (ii) will not cause the Excess Interest Grantor Trust to fail to qualify as a grantor trust under the Code.