Examples of Specific Grantor Trust Assets in a sentence
The Depositor hereby conveys all right, title and interest in and to any VRR Specific Grantor Trust Assets, any Class S Specific Grantor Trust Assets and any other property constituting the Grantor Trust to the Trustee, receipt of which is hereby acknowledged.
In addition, the parties intend that the portion of the Trust Fund consisting of any VRR Specific Grantor Trust Assets and any Class S Specific Grantor Trust Assets will be treated as a grantor trust under subpart E of Part I of subchapter J of the Code.
As provided herein, the Certificate Administrator will elect that two segregated portions of the Trust Fund (other than any VRR Specific Grantor Trust Assets and any Class S Specific Grantor Trust Assets) be treated for federal income tax purposes as two separate REMICs (designated as the “Upper-Tier REMIC” and the “Lower-Tier REMIC”, respectively).
Solely for federal income tax purposes, the Class VRR Certificates and the Uncertificated VRR Interest shall represent undivided beneficial interests in any VRR Specific Grantor Trust Assets, and the Class S Certificates shall represent undivided beneficial interests in any Class S Specific Grantor Trust Assets.
Because the Trust Fund will not include ARD Mortgage Loans as of the Closing Date, there will be no Class S Specific Grantor Trust Assets and the Class S Certificates will not be issued.
For the avoidance of doubt, there are no VRR Specific Grantor Trust Assets and no Class S Specific Grantor Trust Assets, no Grantor Trust shall be established and no Class S Certificates will be issued hereunder.
The Certificate Administrator shall execute and cause to be authenticated and delivered to and upon the order of the Depositor, the Grantor Trust Certificates in exchange for the VRR Specific Grantor Trust Assets and the Class S Specific Grantor Trust Assets.
In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041, Form 1099 or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Certificateholders, their allocable share of income and expense with respect to the related Specific Grantor Trust Assets in the time or times and in the manner required by the Code.
At all times, the Class V-2 Certificates shall collectively represent beneficial ownership interests in the Class V-2 Percentage of the VRR Specific Grantor Trust Assets.
At all times, the Class V-3 Certificates shall collectively represent beneficial ownership interests in the Class V-3 Percentage of the VRR Specific Grantor Trust Assets.