REMIC Tax Opinion definition

REMIC Tax Opinion means an opinion of counsel, acceptable to the Trustee, applicable to the Trust, to the effect that: (i) the execution of and the transactions contemplated by this Agreement will not cause any portion of the Trust for which a REMIC election (as defined in the Internal Revenue Code) has been made in accordance with the applicable Transaction Documents to fail to qualify at any time as a REMIC, and (ii) the receipt of the Payment (as defined herein) by the Trust and application and distribution of the Payment as provided in this Agreement will not cause, or result in, the imposition of any taxes on the Trust or on any portion of the Trust for which a REMIC election has been made in accordance with the terms of the applicable Transaction Documents.
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Examples of REMIC Tax Opinion in a sentence

  • Reasonably promptly following the execution of this Agreement, the Trustee shall use its best efforts to obtain the REMIC Tax Opinion and the Settlement Advice/Opinions in form and substance satisfactory to the Trustee.

  • The Effective Date of this Agreement and the Settlement evidenced hereby shall occur automatically when (a) all of the Settlement Conditions have been met to the satisfaction of the Trustee including, without limitation, the Trustee’s receipt of Final Court Approval, the REMIC Tax Opinion and the Settlement Advice/Opinions, and (b) the Trustee has received the Payment as provided in Section 4 of this Agreement.

  • The “Effective Date” of this Agreement shall be the date upon which the Trustee has received satisfactory direction from Certificateholders in the solicitation, Settlement Expert Opinion, REMIC Tax Opinion, Final Court Approval, and the Escrow Property as provided in Section 3 below.

  • The Settlement Agreement does not become effective, by its terms, until two conditions are satisfied: (i) Final Settlement Court Approval; and (ii) receipt and approval by the Trustee and Trust Administrator of an acceptable REMIC Tax Opinion.

  • The Mexican Museum Report: Fundraising for Expansion” — a report to The Mexican Museum, San Francisco Foundation, and San Francisco Redevelopment Agency, ChangeWeavers, 2003.

Related to REMIC Tax Opinion

  • 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 adversely affect the tax characterization as debt of the Notes of any outstanding Series or Class that were characterized as debt at the time of their issuance, (b) such action will not cause the Issuer 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 Noteholder.

  • Tax Opinions means the opinions of Tax Advisors deliverable to OFC in connection with the Transactions.

  • Unqualified Tax Opinion means an unqualified reasoned “will” opinion of Qualified Tax Counsel, which opinion is reasonably acceptable to each of the Parties and upon which each of the Parties may rely to confirm that a transaction (or transactions) will not result in Distribution Taxes. For purposes of this definition, an opinion is reasoned if it describes the reasons for the conclusions, including the facts and analysis supporting the conclusions.

  • 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.

  • U.S. Tax Certificate has the meaning assigned to such term in Section 2.17(f)(ii)(D)(2).

  • REMIC Trust means a “real estate mortgage investment conduit” within the meaning of Section 860D of the Code that holds the Note.

  • 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.

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

  • IRS Ruling shall have the meaning set forth in the Recitals.

  • United States Tax Compliance Certificate has the meaning specified in Section 3.01.

  • REMIC Provisions means provisions of the federal income tax law relating to real estate mortgage investment conduits, which appear at Sections 860A through 860G of subchapter M of Chapter 1 of the Code, and related provisions, and regulations (including any applicable proposed regulations) and rulings promulgated thereunder, as the foregoing may be in effect from time to time.

  • U.S. Tax Compliance Certificate has the meaning specified in Section 3.01(e)(ii)(B)(III).