Taxable Mortgage Pool. Neither the Company nor any of its assets will be treated as a taxable mortgage pool.
Taxable Mortgage Pool. Neither the Company nor any of its subsidiaries or asset pools is treated as a taxable mortgage pool within the meaning of Section 7701(i) of the Code.
Taxable Mortgage Pool. At no time shall the Company or its assets be treated as a taxable mortgage pool.
Taxable Mortgage Pool. The consummation of the transactions contemplated by this Agreement and the other Transaction documents do not and will not cause the Borrower to be classified as a taxable mortgage pool within the meaning of Section 7701(i) of the Code.
Taxable Mortgage Pool. To the knowledge of the Company, neither the Company, any of its subsidiaries nor any of their assets will be treated as a taxable mortgage pool.
Taxable Mortgage Pool. The Collateral Manager shall not permit the sum of the outstanding principal balances of all Collateral Loans owned by the Borrower and that are principally secured by an interest in real property (within the meaning of Treasury Regulation Section 301.7701(i)-1(d)(3)) to exceed 40% of the Principal Balance of all Collateral Loans owned by the Borrower.
Taxable Mortgage Pool. It shall not permit the sum of the outstanding principal balances of all Collateral Loans owned by the Borrower and that are principally secured by an interest in real property (within the meaning of Treasury Regulation Section 301.7701(i)-1(d)(3)) to exceed 40% of the total aggregate outstanding loan balance of all Collateral Loans owned by the Borrower.
Taxable Mortgage Pool. Neither the Company nor any of its assets is, nor after application of the net proceeds from the Offered Shares as described in the Prospectus will be, treated as a taxable mortgage pool.
Taxable Mortgage Pool. With respect to a Purchased Security, the related Issuer is not a (i) treated as an association taxable as a corporation for federal income tax and relevant state income and franchise tax purposes, (ii) taxable as a taxable mortgage pool as defined in Section 7701(i) of the Code or (iii) taxable as a "publicly traded partnership" as defined in Treasury Regulation section 1.7704-1 for federal income tax purposes and relevant state franchise or income tax purposes.
Taxable Mortgage Pool. Enter into any transaction contemplated by this Agreement that will subject either Borrower to "taxable mortgage pool" status under the regulations of the Internal Revenue Service, as amended.
