Initial Certificate Transfer Opinion means an opinion rendered by nationally recognized tax counsel (i) upon the initial transfer by the Depositor of a Certificate that results in the Issuer being treated as a partnership for United States federal income tax purposes and (ii) while any Note retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes is outstanding that (x) such Note will be debt for United States federal income tax purposes or (y) the transfer by the Depositor of such Certificate will not cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation.
Initial Certificate Transfer Opinion means an opinion rendered by nationally recognized tax counsel (i) upon the initial transfer by the Depositor of a Certificate that results in the Issuer being treated as a partnership for U.S. federal income tax purposes and (ii) while any Note retained by the Issuer or a Person that is considered the same Person as the Issuer for U.S. federal income tax purposes is outstanding that (x) such Notes will be debt for U.S. federal income tax purposes or (y) the transfer by the Depositor of such Certificate will not cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation.
Initial Certificate Transfer Opinion means an Opinion of Counsel rendered by nationally recognized tax counsel (i) upon the initial transfer by the Depositor of a Certificate that results in the Issuer not being wholly owned by the Depositor and (ii) while any Note retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes is outstanding that (x) such Note will be debt for United States federal income tax purposes or (y) the transfer by the Depositor of such Certificate will not cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation, or to be treated as other than a grantor trust for United States federal income tax purposes.
Examples of Initial Certificate Transfer Opinion in a sentence
The restrictions on transfer of Notes retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes provided in Section 2.16(a) shall not continue to apply in the event the Indenture Trustee and the Depositor have received the Initial Certificate Transfer Opinion.
In addition, Traffic Regulation Orders are processed by Divisional staff.
More Definitions of Initial Certificate Transfer Opinion
Initial Certificate Transfer Opinion means an opinion rendered by nationally recognized tax counsel (i) upon the initial transfer by the Depositor of a Certificate that results in the Issuer being treated as a partnership for United States federal income tax purposes and (ii) while any Note retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes is outstanding that (x) such Note will be debt for United States federal income tax purposes or (y) the transfer by the Depositor of such Certificate will not cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation. A-18 Definitions (SDART 2020-1)
Initial Certificate Transfer Opinion means an opinion rendered by nationally recognized tax counsel (i) upon the initial transfer by the Depositor of a Certificate that results in the Issuer being treated as a partnership for federal income tax purposes and (ii) while any Note retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes is outstanding that (x) such Notes will be debt for United States federal income tax purposes and/or (y) the transfer by the Depositor of such Certificate will not cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation. For the sake of clarity, the opinion provided in clause (y) in the preceding sentence would generally be expected, if available, in the event that the opinion provided in clause (x) in the preceding sentence is not rendered with respect to either any outstanding Investment Grade Notes or Non-Investment Grade Notes.
Initial Certificate Transfer Opinion means an opinion rendered by nationally recognized tax counsel (i) upon the initial transfer by the Depositor of a Certificate that results in the Issuer being treated as a partnership for federal income tax purposes and (ii) while any Note retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes is outstanding that (x) such Notes will be debt for United States federal income tax purposes or (y) the transfer by the Depositor of such Certificate will not cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation. 2 (2014-B Amended and Restated Trust Agreement)
Initial Certificate Transfer Opinion means an opinion rendered by nationally recognized tax counsel (i) upon the initial transfer by the Seller of a Certificate to any Person not related to the Administrator and (ii) while any Note as of that date was retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes is outstanding that (x) such Note will be debt for United States federal income tax purposes or (y) the transfer by the Seller of such Certificate will not cause the Issuer or the Grantor Trust to be treated as an association or publicly traded partnership taxable as a corporation, and will not cause the Grantor Trust to be treated as other than a grantor trust for United States federal income tax purposes.
Initial Certificate Transfer Opinion means an opinion rendered by nationally recognized tax counsel (i) upon the initial transfer by the Depositor of a Certificate that results in the Issuer being treated as a partnership for United States federal income tax purposes and (ii) while any Note retained by the Issuer or a Person that is considered the same Person as the Issuer for United States federal income tax purposes is outstanding that (x) such Note will be debt for United States federal income tax purposes or (y) the transfer by the Depositor of such Certificate will not cause the Issuer to be treated as an association or publicly traded partnership taxable as a corporation. “ Initial Class A Note Balance ” means $271,640,000. “ Initial Class B Note Balance ” means $88,700,000. “ Initial Purchasers ” means BMO Capital Markets Corp. and SMBC Nikko Securities America, Inc. “ Initial Reserve Account Deposit Amount ” means an amount equal to $ 11 , 087 , 384 . 86 .
Initial Certificate Transfer Opinion. An opinion rendered by counsel satisfactory to the Depositor that (i) upon the initial transfer by the Depositor of an interest in the Certificates and (ii) while any Restricted Note is outstanding, (x) such Note will be characterized as indebtedness for United States federal income tax purposes and (y) such transfer of the Certificate by the Depositor will not cause the Issuing Entity to fail to qualify as a grantor trust for United States federal income tax purposes. [Initial Closing Date: [ ].] [Initial Cutoff Date: [ ]].
Initial Certificate Transfer Opinion. An opinion rendered by counsel satisfactory to the Depositor that (i) upon the initial transfer by the Depositor of an interest in the Certificates and (ii) while any Retained Note is outstanding, (x) such Note will be characterized as indebtedness for United States federal income tax purposes and (y) such transfer of the Certificate by the Depositor will not cause the Issuing Entity to fail to qualify as a grantor trust for United States federal income tax purposes. [Initial Closing Date: [ ].] [Initial Cutoff Date: [ ]]. App. A-18 [Initial Purchased Property: As defined in Section 2.01(a) of the Pooling Agreement.] [Initial Receivables: Any retail instalment sale contract or direct purchase money loan for a Financed Vehicle that is included in the Schedule of Initial Receivables attached to the First Step Initial Receivables Assignment and all rights and obligations thereunder.]