We represent that. (a) We understand that the Residual Certificate represents for federal income tax purposes a "residual interest" in a real estate mortgage investment conduit. (b) We understand that as the holders of the Residual Certificate we will be required to take into account, in determining our taxable income, our pro rata percentage interest of the taxable income of REMIC I, REMIC II and REMIC III in accordance with all applicable provisions of the Internal Revenue Code of 1986, as amended (the "Code").
Appears in 1 contract
Sources: Trust Agreement (Gs Mortgage Securities Corp Mort Pas Thru CRTS Sries 2003-1)
We represent that. (a) We we understand that the Residual Certificate represents for federal income tax purposes a "residual interest" in a real estate mortgage investment conduit.; and
(b) We we understand that as the holders holder of the a Residual Certificate we will be required to take into account, in determining our taxable income, our pro rata percentage interest of the taxable income of the applicable Trust REMIC I, REMIC II and REMIC III in accordance with all applicable provisions of the Internal Revenue Code code of 1986, as amended (the "Code").
Appears in 1 contract
Sources: Pooling and Servicing Agreement (Prudential Securities Secured Financing Corp)
We represent that. (a) We understand that the Residual Certificate represents for federal income tax purposes a "residual interest" in a real estate mortgage investment conduit.
(b) We understand that as the holders holder of the Residual Certificate we will be required to take into account, in determining our taxable income, our pro rata percentage interest of the taxable income of the Trust REMIC I, REMIC II and REMIC III in accordance with all applicable provisions of the Internal Revenue Code of 1986, as amended (the "Code").
Appears in 1 contract
Sources: Trust and Servicing Agreement (Kranzco Realty Trust)
We represent that. (a) We we understand that the Residual Certificate represents for federal income tax purposes a "residual interest" in a real estate mortgage investment conduit.; and
(b) We we understand that as the holders holder of the a Residual Certificate we will be required to take into account, in determining our taxable income, our pro rata percentage interest of the taxable income of the applicable Trust REMIC I, REMIC II and REMIC III in accordance with all applicable provisions of the Internal Revenue Code code of 1986, as amended (the "Code").
Appears in 1 contract
Sources: Pooling and Servicing Agreement (Prudential Securities Secured Financing Corp)