Tax Classification of the Excess Reserve Fund Account and the Supplemental Interest Trust. For federal income tax purposes, the Securities Administrator shall treat the Excess Reserve Fund Account and the Supplemental Interest Trust as beneficially owned by the holders of the Class X Certificates and shall treat such portion of the Trust Fund as a grantor trust, within the meaning of subpart E, Part I of subchapter J of the Code.
Appears in 14 contracts
Samples: Pooling and Servicing Agreement (HSI Asset Securitization CORP Trust 2006-Wmc1), Pooling and Servicing Agreement (First Franklin Mortgage Loan Trust 2006-Ff5), Pooling and Servicing Agreement (HSI Asset Loan Obligation Trust 2007-Wf1)
Tax Classification of the Excess Reserve Fund Account and the Supplemental Interest Trust. For federal income tax purposes, the Securities Administrator shall treat the Excess Reserve Fund Account and the Supplemental Interest Trust as beneficially owned by the holders a disregarded entity for so long as a single holder owns all of the Class X Certificates and shall treat such portion of the Trust Fund as a grantor trust, within the meaning of subpart E, Part I of subchapter J of the CodeCertificates.
Appears in 2 contracts
Samples: Pooling and Servicing Agreement (HSI Asset Securitization CORP Trust 2007-Nc1), Pooling and Servicing Agreement (HASCO Trust 2007-He2)
