Common use of TAX CLASSIFICATION OF CERTAIN ACCOUNTS Clause in Contracts

TAX CLASSIFICATION OF CERTAIN ACCOUNTS. For federal income tax purposes, the Trustee shall treat the Excess Reserve Fund Account as an outside reserve fund, within the meaning of Treasury Regulation ss. 1.860G-2(h), that is beneficially owned by the holder of the Class X Certificate. The Trustee shall treat the rights that each Class of Certificates has to receive payments of Basis Risk Carry Forward Amounts from the Excess Reserve Fund Account as rights to receive payments under an interest rate cap contract written by the Class X Certificateholder in favor of each Class. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will comprise two components - an Upper Tier Regular Interest and an interest in a notional principal contract. The Trustee shall allocate the issue price for a Class of Certificates between such two components for purposes of determining the issue price of the Upper Tier Regular Interest component based on information received from the Depositor.

TAX CLASSIFICATION OF CERTAIN ACCOUNTS. For federal income tax purposes, the Trustee shall treat the Excess Reserve Fund Account as an outside reserve fund, within the meaning of Treasury Regulation ss. 1.860G-2(h), that is beneficially owned by the holder of the Class X Certificate. The Trustee shall treat the rights that each Class of Certificates has to receive payments of Basis Risk Carry Forward CarryForward Amounts from the Excess Reserve Fund Account as rights to receive payments under an interest rate cap contract written by the Class X Certificateholder in favor of each Class. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will comprise two components - an Upper Tier Regular Interest and an interest in a notional principal contract. The Trustee shall allocate the issue price for a Class of Certificates between such two components for 114 purposes of determining the issue price of the Upper Tier Regular Interest component based on information received from the Depositor.

TAX CLASSIFICATION OF CERTAIN ACCOUNTS. For federal income tax purposes, the Trustee shall treat the Excess Reserve Fund Account as an outside reserve fund, within the meaning of Treasury Regulation ss. 1.860G-2(h), that is beneficially owned by the holder of the Class X Certificate. The ThE Trustee shall treat the rights that each Class of Certificates has to receive payments of Basis Risk Carry Forward CarryForward Amounts from the Excess Reserve Fund Account as rights to receive payments under an interest rate cap contract written by the Class X Certificateholder in favor of each Class. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will comprise two components - an Upper Tier Regular Interest and an interest in a notional principal cap contract. The Trustee shall allocate the issue price for a Class of Certificates between such two components for purposes of 106 determining the issue price of the Upper Tier Regular Interest component based on information received from the Depositor.

TAX CLASSIFICATION OF CERTAIN ACCOUNTS. For federal income tax purposes, the Trustee shall treat the Excess Reserve Fund Account as an outside reserve fund, within the meaning of Treasury Regulation ss. 1.860G-2(h), that is beneficially owned by the holder of the Class X Certificate. The Trustee shall treat the rights that each Class of Certificates has to receive payments of Basis Risk Carry Forward CarryForward Amounts from the Excess Reserve Fund Account as rights to receive payments under an interest rate cap contract written by the Class X Certificateholder in favor of each Class. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will comprise two components - an Upper Tier Regular Interest and an interest in a notional principal contract. The Trustee shall allocate the issue price for a Class of Certificates between such two components for purposes of determining the issue price of the Upper Tier Regular Interest component based on information received from the Depositor.

TAX CLASSIFICATION OF CERTAIN ACCOUNTS. For federal income tax purposes, the Trustee shall treat the Excess Reserve Fund Account as an outside reserve fund, within the meaning of Treasury Regulation ss. 1.860G-2(h1.860-2(h), that is beneficially owned by the holder of the Class X Certificate. The Trustee shall treat the rights that each Class of Certificates has to receive payments of Basis Risk Carry Forward CarryForward Amounts from the Excess Reserve Fund Account as rights to receive payments under an interest rate cap contract written by the Class X Certificateholder in favor of each Class. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will comprise two components - an Upper Tier Regular Interest and an interest in a notional principal cap contract. The Trustee shall allocate the issue price for a Class of Certificates between such two components for purposes of determining the issue price of the Upper Tier Regular Interest component based on information received from the Depositor.

TAX CLASSIFICATION OF CERTAIN ACCOUNTS. For federal income tax purposes, the Trustee shall treat the Excess Reserve Fund Account as an outside reserve fund, within the meaning of Treasury Regulation ss. (Section) 1.860G-2(h), that is beneficially owned by the holder of the Class X Certificate. The Trustee shall treat the rights that each Class of Certificates has to receive payments of Basis Risk Carry Forward CarryForward Amounts from the Excess Reserve Fund Account as rights to receive payments under an interest rate cap contract written by the Class X Certificateholder in favor of each Class. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will comprise two components - an Upper Tier Regular Interest and an interest in a notional principal contract. The Trustee shall allocate the issue price for a Class of Certificates between such two components for purposes of determining the issue price of the Upper Tier Regular Interest component based on information received from the Depositor.

TAX CLASSIFICATION OF CERTAIN ACCOUNTS. For federal income tax purposes, the Trustee shall treat the Excess Reserve Fund Account as an outside reserve fund, within the meaning of Treasury Regulation ss. Section 1.860G-2(h), that is beneficially owned by the holder of the Class X Certificate. The Trustee shall treat the rights that each Class of Certificates has to receive payments of Basis Risk Carry Forward CarryForward Amounts from the Excess Reserve Fund Account as rights to receive payments under an interest rate cap contract written by the Class X Certificateholder in favor of each Class. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will comprise two components - an Upper Tier Regular Interest and an interest in a notional principal contract. The Trustee shall allocate the issue price for a Class of Certificates between such two components for purposes of determining the issue price of the Upper Tier Regular Interest component based on information received from the Depositor.