Federal Income Tax Allocations Sample Clauses

Federal Income Tax Allocations. If the Certificates have more than one beneficial owner for United States federal income tax purposes, then for United States federal income tax purposes each item of income, gain, loss, credit and deduction for a month shall be allocated to the Certificateholders as of the first Record Date following the end of such month in proportion to their Percentage Interests on such Record Date. The Depositor (or the Administrator in accordance with the Administration Agreement and Section 5.3) is authorized, in its sole discretion, (i) to modify the allocations in this paragraph if necessary or appropriate for the allocations to fairly reflect the economic income, gain or loss to the Certificateholders or otherwise comply with the requirements of the Code and (ii) to determine whether or not to make any available tax elections such as an election under Sections 1278 or 754 of the Code.

Federal Income Tax Allocations. To the extent required for federal income tax purposes, net income or net losses of the Trust for any month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Certificateholders in proportion to their interests (to the extent not previously allocated pursuant to this clause). The Depositor is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion for the allocations to fairly reflect the economic income, gain or loss to the Certificateholders, as otherwise required by the Code.

Federal Income Tax Allocations. Net income of the Trust with respect to any Loan Group for any Collection Period as determined for Federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (a) among the holders of the Trust Certificates as of the close of business on the last day of such Collection Period, in proportion to their ownership of principal amount of Trust Certificates on such date, an amount of net income up to the sum of (i) the portion of the Certificateholders' Interest Distribution Amount and the Certificateholders' Interest Index Carryover if any, for the related Distribution Date allocable to such Collection Period, (ii) interest on the excess, if any, of the Certificateholders' Interest Distribution Amount for the preceding Distribution Date over the amount in respect of interest that is actually distributed to such holders of the Trust Certificates on such preceding Distribution Date, to the extent permitted by law, at the Certificate Rate for such Collection Period and (iii) the portion of the market discount on the Financed Student Loans accrued during such quarter that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price; and (b) to the Depositor, to the extent of any remaining net income. If the net income of the Trust for any month is insufficient for the allocations described in clause (a) above, subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in the preceding sentence. Net losses of the Trust if any, for any month as determined for Federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor to the extent the Depositor is reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the remaining holders of the Trust Certificates as of the close of business on the last day of such month in proportion to their ownership of principal amount of Trust Certificates on such Record Date. The Depositor is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain or loss to the Depositor or to the holders of the Trust Certificates, or as otherwise required by the Code.

Federal Income Tax Allocations. Net income of the Trust for any month, as determined for Federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof), shall be allocated to the Transferor.

Federal Income Tax Allocations. Net income of the Trust for any month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) during which the beneficial ownership interests in the Trust are held by more than one Person shall be allocated: (a) in an amount equal to any amount distributed to the Certificateholders pursuant to the Sale and Servicing Agreement (to the extent not previously allocated pursuant to this clause); and (b) to the Depositor, to the extent of any remaining net income. If the net income of the Trust for any month is insufficient for the allocations described in clause (a) above, subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in the preceding sentence. Net losses of the Trust, if any, for any month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor to the extent the Depositor has agreed hereunder and under the Sale and Servicing Agreement and the Indenture to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificateholders as of the first Distribution Date following the end of such month in proportion to their ownership of principal amount of Certificates as of the close of business on such Distribution Date. The Depositor is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain or loss to the Depositor or to the Certificateholders, or as otherwise required by the Code.

Federal Income Tax Allocations. If the Trust Certificates are beneficially owned by more than one Person (and all such owners are not treated as the same Person for U.S. federal income tax purposes), for U.S. federal income tax purposes each item of income, gain, loss, credit and deduction for a month shall be allocated to the Certificateholders as of the first Record Date following the end of such month in proportion to their Certificate Percentage Interests on such Record Date. The Trust (or the Administrator in accordance with the Administration Agreement and Section 5.04) is authorized to (i) modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain or loss to the Certificateholders or otherwise comply with the requirements of the Code and (ii) determine whether or not to make any available elections such as an election under Section 1278 or 754 of the Code.

Federal Income Tax Allocations. Net income of the Trust for any period, as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof), shall be allocated to the Certificateholders on a pro rata basis in accordance with their respective Percentage Interests.

Federal Income Tax Allocations. (a) Net income of the Trust for any month, as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof), shall be allocated: (i) among the Certificate Owners as of the first day following the end of such month, in proportion to their ownership of the principal amount of Certificates on such date, net income in an amount up to the sum of (A) the Certificate Interest Distributable Amount for such month, (B) interest on the excess, if any, of the Certificate Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Certificate Rate from such preceding Distribution Date through the current Distribution Date, (C) the portion of the market discount on the Contracts accrued during such month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price and (D) any other amounts of income payable to the Certificateholders for such month; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (ii) among the Residual Interestholders in proportion to the Percentage Interest of the Residual Interest of each Residual Interestholder, to extent of any remaining net income. (b) If the net income of the Trust for any calendar month is insufficient for the allocations described in Section 2.10(a)(i), subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.10(a)(ii). Net losses of the Trust, if any, for any calendar month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Residual Interestholders, to the extent the Residual Interestholders are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day following the end of such month in proportion to their ownership of the principal amount of Certificates on such day. Any indebtedness allocated pursuant to Treasury Regulation Section 1.752-3(a)(3) shall be allocated to the Re...

Federal Income Tax Allocations. If the Trust Certificates are held by more than one Person, for federal income tax purposes each item of income, gain, loss, credit and deduction shall be allocated to the Certificateholders as of the first Record Date following the end of such month in proportion to their Certificate Percentage Interests on such Record Date. The Depositor is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain or loss to the Certificateholders or otherwise required by the Code. Notwithstanding anything provided in this Section, if the Trust Certificates are held solely by the Depositor, the application of this Section shall be disregarded.

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated among the Certificateholders as of the first day following the end of such quarter, in proportion to their Certificate Percentage Interest on such date, net income in an amount up to the sum any other amounts of income payable to the Certificateholders for such quarter. (b) Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Certificateholders in proportion to their Certificate Percentage Interest as of the first day following the end of such quarter in proportion to their Certificate Percentage Interest on such day. The Certificateholders are authorized to modify the allocations in this paragraph if necessary or appropriate, in their sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Certificateholders, or as otherwise required by the Code. ARTICLE THREE