Treatment of Notes as Debt for Tax Purposes. The Issuer shall treat the Notes as indebtedness for all federal, state and local income and franchise tax purposes.
Treatment of Notes as Debt for Tax Purposes. The Issuer shall, and shall cause the Administrator to, treat the Notes as indebtedness for all purposes.
Treatment of Notes as Debt for Tax Purposes. For purposes of federal, state and local income, franchise and any other income taxes, the Trust will treat the Notes as indebtedness, and hereby instructs the Indenture Trustee, Payee Agent and the Servicer, on behalf of the Trust to treat the Notes as indebtedness for all applicable tax reporting purposes.
Treatment of Notes as Debt for Tax Purposes. The Issuer shall, and shall cause the Trust Administrator and the Master Servicer to, treat the Notes as indebtedness for all federal, state and local income, single business, and franchise tax purposes.
Treatment of Notes as Debt for Tax Purposes. 16 Section 3.13. Notice of Events of Default 16 Section 3.14. Further Instruments and Acts 17 Section 3.15. Representation and Warranties of the Issuer. 17
Treatment of Notes as Debt for Tax Purposes. 18 Section 3.13. Notice of Events of Default. 18
Treatment of Notes as Debt for Tax Purposes. 64 SECTION 8.10. Further Instruments and Acts. 64
Treatment of Notes as Debt for Tax Purposes. For purposes of federal, state and local income, single business and franchise taxes, the Issuing Entity will treat the Class A and Class M Notes, other than such Notes held by the Depositor or its owner, as indebtedness, and hereby instructs the Indenture Trustee, Paying Agent and the Servicer, on behalf of the Issuing Entity to treat the Class A and Class M Notes, other than such Notes held by the Depositor or its owner, as indebtedness for all applicable tax reporting purposes. For purposes of federal, state and local income, single business and franchise taxes, the Issuing Entity will treat the Class X Notes as “stripped coupons” within the meaning of section 1286 of the Code, and hereby instructs the Indenture Trustee, Paying Agent and the Servicer, on behalf of the Issuing Entity to treat the Class X Notes as “stripped coupons” for all applicable tax reporting purposes. Notwithstanding anything herein to the contrary, payments of Available Funds Cap Shortfalls made pursuant to Section 8.01(c)(i) and (ii) hereof will be treated by the Issuing Entity, the Indenture Trustee, the Paying Agent and the Servicer as having been made pursuant to a “notional principal contract” within the meaning of Treasury regulation section 1.446-3 written by the holders of the Class X Notes in favor of holders of the Class A and Class M Notes for all applicable tax reporting purposes.
Treatment of Notes as Debt for Tax Purposes. The Trust shall treat the Notes as indebtedness for all federal and state tax purposes.
Treatment of Notes as Debt for Tax Purposes. 61 SECTION 8.9. Hedge Agreements. 61
