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.

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.