Common use of Tax Treatment of the Notes Clause in Contracts

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 Notes in some other manner pursuant to a Final Tax Determination.

Appears in 5 contracts

Samples: Debt Agreement, Debt Agreement, Debt Agreement

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Tax Treatment of the Notes. (a) By purchasing Class 1M-1 2M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 2B-1 Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 2B-1 Notes in some other manner pursuant to a Final Tax Determination.

Appears in 5 contracts

Samples: Debt Agreement, Debt Agreement, Debt Agreement

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 2M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 2B Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 2B Notes in some other manner pursuant to a Final Tax Determination.

Appears in 3 contracts

Samples: Global Agency Agreement, Debt Agreement, Debt Agreement

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 1B Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 1B Notes in some other manner pursuant to a Final Tax Determination.

Appears in 3 contracts

Samples: Debt Agreement, Debt Agreement, Global Agency Agreement

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae Xxx and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 Notes in some other manner pursuant to a Final Tax Determination.

Appears in 2 contracts

Samples: Debt Agreement, Debt Agreement

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx Mae will treat the Class 1B-1 1B Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 1B Notes in some other manner pursuant to a Final Tax Determination.

Appears in 1 contract

Samples: Debt Agreement

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae Xxx and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 1B Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 1B Notes in some other manner pursuant to a Final Tax Determination.

Appears in 1 contract

Samples: Debt Agreement

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Tax Treatment of the Notes. (a) By purchasing Class 1M-1 Notes or Class 2M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 1B Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 1B Notes in some other manner pursuant to a Final Tax Determination.

Appears in 1 contract

Samples: Debt Agreement

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 2M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae Xxx and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx will treat the Class 1B-1 2B-1 Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 2B-1 Notes in some other manner pursuant to a Final Tax Determination.

Appears in 1 contract

Samples: Debt Agreement

Tax Treatment of the Notes. (a) By purchasing Class 1M-1 Notes or exchanging for or purchasing Exchangeable Notes, the Holders and Beneficial Owners agree to treat such Notes as indebtedness of Xxxxxx Xxx Mae for U.S. federal income tax purposes, unless such Holders or Beneficial Owners are required to treat such Notes in some other manner pursuant to a final determination by the U.S. Internal Revenue Service or by a court of competent jurisdiction (each, a "Final Tax Determination"). Holders and Beneficial Owners further agree to prepare their U.S. federal income tax returns on the basis that such Notes will be treated as indebtedness of Xxxxxx Mae Xxx and to report items of income, deduction, gain or loss with respect to such Notes in a manner consistent with the information reported to them pursuant to Section 3.01(c), unless otherwise required pursuant to a Final Tax Determination (b) Xxxxxx Xxx Mae will treat the Class 1B-1 Notes as notional principal contracts for U.S. federal income tax purposes (except for U.S. withholding tax purposes) and, as a result, as (i) a deemed loan and (ii) an on-market swap, each of which is tax accounted for in the manner described in the Prospectus, unless required to treat the Class 1B-1 Notes in some other manner pursuant to a Final Tax Determination.

Appears in 1 contract

Samples: Debt Agreement

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