Tax Opinion. This Indenture may not be amended under this Article or otherwise unless, in connection with the amendment, an Opinion of Counsel is furnished to the Indenture Trustee that the amendment will not (i) adversely affect the status of the Notes as debt, or cause the beneficial owners of the Note to recognize gain or loss, for federal income or applicable state tax purposes; (ii) result in the Trust being taxable at the entity level; or (iii) result in the Trust being classified as a taxable mortgage pool (as defined in Section 7701(i) of the Code).
Appears in 23 contracts
Samples: Custodial Agreement (CWABS Revolving Home Equity Loan Trust, Series 2004-N), Custodial Agreement (CWHEQ Revolving Home Equity Loan Asset Backed Notes, Series 2005-C), Custodial Agreement (CWABS Revolving Home Equity Loan Trust, Series 2004-J)
Tax Opinion. This Indenture may not be amended under this Article or otherwise unless, in connection with the amendment, an Opinion of Counsel is furnished to the Indenture Trustee that the amendment will not (i) adversely affect the status of the Notes as debt, or cause the beneficial owners of the Note to recognize gain or loss, for federal income or applicable state tax purposes; (ii) result in the Trust being taxable at the entity level; or (iii) result in the Trust being classified as a taxable mortgage pool (as defined in Section 7701(i) of the Code).
Appears in 16 contracts
Samples: Indenture (Cwabs Inc Revolving Home Eq Loan Ast Back Notes Ser 2003-D), Indenture (Cwabs Inc), Indenture (Cwabs Inc)
Tax Opinion. This Indenture may not be amended under this Article or otherwise unless, in connection with the amendment, an Opinion of Counsel is furnished to the Indenture Trustee and the Credit Enhancer that the amendment will not (i) adversely affect the status of the Notes as debt, or cause the beneficial owners of the Note to recognize gain or loss, for federal income or applicable state tax purposes; (ii) result in the Trust being taxable at the entity level; or (iii) result in the Trust being classified as a taxable mortgage pool (as defined in Section 7701(i) of the Code).
Appears in 5 contracts
Samples: Custodial Agreement (CWABS Revolving Home Equity Loan Trust, Series 2004-I), Custodial Agreement (CWHEQ Revolving Home Equity Loan Asset Backed Notes, Series 2005-E), Custodial Agreement (CWHEQ Revolving Home Equity Loan Asset Backed Notes, Series 2005-A)
Tax Opinion. This Indenture may not be amended under this Article or otherwise unless, in connection with the amendment, an Opinion of Counsel is furnished to the Indenture Trustee and the Credit Enhancer that the amendment will not (i) adversely affect the status of the Notes as debt, or cause the beneficial owners of the Note to recognize gain or loss, for federal income or applicable state tax purposes; (ii) result in the Trust being taxable at the entity level; or (iii) result in the Trust being classified as a taxable mortgage pool (as defined in Section 7701(i) of the Code).
Appears in 2 contracts
Samples: Indenture (Cwabs Inc), Indenture (Cwabs Inc)
Tax Opinion. This Indenture may not be amended under this Article or otherwise unless, in connection with the amendment, an Opinion of Counsel is furnished to the Indenture Trustee that the amendment will not (i) adversely affect the status of the Notes as debt, or cause the beneficial owners of the Note to recognize gain or loss, for federal income or applicable state tax purposes; (ii) result in the Trust being taxable at the entity level; or (iii) result in the Trust being classified as a taxable mortgage pool (as defined in Section 7701(i) of the Code).or
Appears in 1 contract
Samples: Custodial Agreement (Cwabs Inc Revolving Home Equity Loan Notes Series 2004-C)
Tax Opinion. This Indenture may not be amended under this Article or otherwise unless, in connection with the amendment, an Opinion of Counsel is furnished to the Indenture Trustee that the amendment will not (i) adversely affect the status of the Notes as debt, or cause the beneficial owners of the Note to recognize gain or loss, for federal income or applicable state tax purposes; purposes (ii) result in the Trust being taxable at the entity level; or (iii) result in the Trust being classified as a taxable mortgage pool (as defined in Section 7701(i) of the Code).
Appears in 1 contract
Samples: Custodial Agreement (Cwabs Master Trust Series 2004-B)
