Common use of Federal Income Tax Treatment Clause in Contracts

Federal Income Tax Treatment. The Depositor, the Servicer, the Owner Trustee and each Noteholder agree to treat, and to take no action inconsistent with the treatment of, the Notes as indebtedness for purposes of federal, state, local and foreign income or franchise taxes and any other tax imposed on or measured by income. Each Noteholder, by acceptance of its Note, agrees to be bound by the provisions of this Section 2.11. Each Noteholder agrees that it will cause any Note Owner acquiring an interest in a Note through it to comply with this Agreement as to the treatment of the Notes as indebtedness under applicable tax law, as described in this Section 2.11. Furthermore, subject to Section 4.1, the Depositor and the Trustee shall treat the Trust as a security device only, and shall not file tax returns or obtain an employer identification number on behalf of the Trust. In the event that any class of Notes is deemed for federal income tax purposes to represent an equity interest in the Trust, the Trust shall be treated for federal income tax purposes as a partnership among the Holders of such Notes and the Depositor. In the event such a partnership is deemed to exist, the 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:

Federal Income Tax Treatment. The DepositorSeller has structured this Agreement and the Investor Certificates with the intention that the Investor Certificates will qualify under applicable federal, state, local and foreign tax law as indebtedness. The Seller, the Servicer, the Owner Trustee General Partner, and each Noteholder Investor Certificateholder agree to treat, treat and to take no action inconsistent with the treatment of, of the Notes Investor Certificates (or beneficial interest therein) as indebtedness for purposes of federal, state, local and foreign income or franchise taxes and any other tax imposed on or measured by income. Each NoteholderInvestor Certificateholder, by acceptance of its NoteCertificate, agrees and the General Partner, agree to be bound by the provisions of this Section 2.11. Each Noteholder agrees that it will cause any Note Owner acquiring an interest in a Note through it to comply with this Agreement as to the treatment of the Notes as indebtedness under applicable tax law, as described in this Section 2.11. Furthermore, subject to Section 4.15.5, the Depositor and the Trustee shall treat the Trust as a security device only, and shall not file tax returns or obtain an employer identification number on behalf of the Trust. In the event that any class of Notes is the Investor Certificates are deemed for federal income tax purposes to represent an equity interest in the Trust, the Trust shall be treated for federal income tax purposes as a partnership among the Holders of such Notes Investor Certificates and the DepositorSeller. In the event such a partnership is deemed to exist, the 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: