Additional Limitation on Action and Imposition of Tax. Any provision of this Agreement to the contrary notwithstanding, the Grantor Trustee shall not, without having obtained an opinion of counsel experienced in federal income tax matters acceptable to the Certificate Insurer to the effect that such transaction does not result in a tax imposed on the Trust (i) sell any assets in the Trust Estate, (ii) accept any contribution of assets after the Startup Day or (iii) agree to any modification of this Agreement.
Appears in 2 contracts
Sources: Grantor Trust Agreement (Contisecurities Asset Funding Corp), Grantor Trust Agreement (Contimortgage Home Equity Trust 1997-5)
Additional Limitation on Action and Imposition of Tax. Any provision of this Agreement to the contrary notwithstanding, the Grantor Trustee shall not, without having obtained an opinion of counsel experienced in federal income tax matters acceptable to the Certificate Insurer to the effect that such transaction does not result in a tax imposed on the Trust (i) sell any assets in the Trust Estate, (ii) accept any contribution of assets after the Startup Day or (iii) agree to any amendment or modification of this Agreement.
Appears in 1 contract
Sources: Grantor Trust Agreement (Credit Suisse First Boston Mortgage Securities Corp)