REMIC Opinion. An Opinion of Counsel stating that, under the REMIC Provisions, any contemplated action will not cause REMIC I or REMIC II to fail to qualify as a REMIC or result in the imposition of a tax upon the Trust Fund (including but not limited to the tax on prohibited transactions as defined in Section 860F(a)(2) of the Code and the tax on contributions to a REMIC set forth in Section 860G(d) of the Code).
Appears in 5 contracts
Samples: Pooling and Servicing Agreement (Merrilll Lynch Mortgage Investors Trust, Series 2005-A10), Pooling and Servicing Agreement (Merrill Lynch Mortgage Investors Trust, Series 2005-A7), Pooling and Servicing Agreement (Merrilll Lynch Mortgage Investors Trust, Series 2005-A10)
REMIC Opinion. An Opinion of Counsel stating thatIndependent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, any contemplated action will not (i) cause REMIC I or REMIC II to fail to qualify as a REMIC or while any regular interest in such REMIC is outstanding, (ii) result in the imposition of a tax upon the Trust Fund (including but not limited to the tax on prohibited transactions as defined in Section 860F(a)(2with respect to any REMIC or (iii) of constitute a taxable contribution to any REMIC after the Code and the tax on contributions to a REMIC set forth in Section 860G(d) of the Code)Startup Day.
Appears in 4 contracts
Samples: Pooling and Servicing Agreement (Structured Asset Mortgage Investments Inc), Pooling and Servicing Agreement (Structured Asset Mortgage Investments Inc), Pooling and Servicing Agreement (Thornburg Mortgage Securities Trust 2004-4)
REMIC Opinion. An Opinion of Counsel stating that, under the REMIC Provisions, any contemplated action will not cause the REMIC I or REMIC II Trust to fail to qualify as a REMIC or result in the imposition of a tax upon the Trust Fund (including but not limited to the tax on prohibited transactions as defined in Section 860F(a)(2) of the Code and the tax on contributions to a the REMIC Trust set forth in Section 860G(d) of the Code).
Appears in 3 contracts
Samples: Pooling and Servicing Agreement (Merrill Lynch Mortgage Investors Trust, Series 2005-A5), Pooling and Servicing Agreement (Merrill Lynch Mortgage Investors Trust, Series 2005-A5), Pooling and Servicing Agreement (MERRILL LYNCH MORT INV TRUST MLMI Series 2005-A2)
REMIC Opinion. An Opinion of Counsel stating that, under the REMIC Provisions, any contemplated action will not cause any REMIC I or REMIC II to fail to qualify as a REMIC or result in the imposition of a tax upon the Trust Fund (including but not limited to the tax on prohibited transactions as defined in Section 860F(a)(2) of the Code and the tax on contributions to a REMIC set forth in Section 860G(d) of the Code).
Appears in 3 contracts
Samples: Pooling and Servicing Agreement, Pooling and Servicing Agreement (Deutsche Alt-a Securities Mortgage Loan Trust, Series 2006-Ar5), Pooling and Servicing Agreement (Deutsche Alt-a Securities, Inc. Mortgage Loan Trust, Series 2005-1)
REMIC Opinion. An Opinion of Counsel stating that, under the REMIC Provisions, any contemplated action will not cause REMIC I , REMIC II or REMIC II III to fail to qualify as a REMIC or result in the imposition of a tax upon the Trust Fund (including but not limited to the tax on prohibited transactions as defined in Section 860F(a)(2) of the Code and the tax on contributions to a REMIC set forth in Section 860G(d) of the Code).
Appears in 2 contracts
Samples: Assignment Agreement (Merrill Lynch Mortgage Investors Trust, Series 2005-A4), Pooling and Servicing Agreement (Merrill Lynch Mortgage Investor Trust Series MLCC 2005-3)
