Common use of Opinion Clause in Contracts

Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, (ii) cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;

Appears in 44 contracts

Samples: Indenture (Ford Credit Auto Owner Trust 2017-B), Indenture (Ford Credit Auto Owner Trust 2022-A), Indenture (Ford Credit Auto Owner Trust 2017-A)

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Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, (ii) cause the Issuer or a Titling Company to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;

Appears in 30 contracts

Samples: Indenture (Ford Credit Auto Lease Trust 2023-B), Indenture (Ford Credit Auto Lease Trust 2020-A), Indenture (Ford Credit Auto Lease Trust 2020-B)

Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not cause (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, Code or (ii) cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;

Appears in 25 contracts

Samples: Transfer and Servicing Agreement (Verizon Owner Trust 2020-B), Indenture (Verizon Owner Trust 2020-C), Transfer and Servicing Agreement (Verizon Owner Trust 2020-A)

Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the mergerconsolidation, consolidation merger or transfer will not cause (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, Code or (ii) cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;

Appears in 5 contracts

Samples: Indenture (Ford Credit Auto Receivables Two LLC), Indenture (Ford Credit Auto Receivables Two LLC), Indenture (Ford Credit Auto Receivables Two LLC)

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Opinion. The Issuer has received an Opinion of Counsel (with a copy to the Indenture Trustee) stating that the merger, consolidation or transfer will not cause (i) cause any security issued by the Issuer to be deemed sold or exchanged for purposes of Section 1001 of the Code, Code or (ii) cause the Issuer or a Titling Company to be treated as an association or publicly traded partnership taxable as a corporation for U.S. federal income tax purposes or (iii) adversely affect the treatment of the Notes as debt for U.S. federal income tax purposes;

Appears in 5 contracts

Samples: Indenture (CAB East LLC), Indenture (CAB East LLC), Indenture (Ford Credit Auto Lease Two LLC)

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