Creation of the Grantor Trust Clause Samples
Creation of the Grantor Trust. The Class NR Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of Excess Interest and the Excess Interest Distribution Account and proceeds thereof and the Class EC Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for the Class EC Certificates and the Class EC Distribution Account, which portions shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code. For federal income tax purposes, the regular interests in the Upper-Tier REMIC represented by the classes of Exchangeable Certificates (or portions thereof) that have been exchanged for Class EC Certificates shall be deemed to continue to be outstanding and represented by the Class EC Certificates, and upon a reconversion of Class EC Certificates for Exchangeable Certificates, shall again be deemed to be represented by such Exchangeable Certificates.
Creation of the Grantor Trust. Each Class of Exchangeable Certificates, the Class V Certificates and the VRR Interest are hereby designated as undivided beneficial interests in their corresponding Grantor Trust Designated Portions, which portions shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code.
Creation of the Grantor Trust. The Class NR Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of Excess Interest and the Excess Interest Distribution Account and proceeds thereof, which portion shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code.
Creation of the Grantor Trust. The Class V Certificates and the RR Interest are hereby designated as undivided beneficial interests in their respective portions of the Trust Fund consisting of their interests in the Class V Specific Grantor Trust Assets and the RR Interest Specific Grantor Trust Assets, respectively, which portions shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code.
Creation of the Grantor Trust. The parties hereto will treat the Grantor Trust as a grantor trust for federal income tax purposes, and the Class ELP Certificates as representing undivided beneficial interests in the Grantor Trust consisting of the Excess Liquidation Proceeds Option. As provided herein, the Certificate Administrator shall take all actions expressly required hereunder to ensure that the portion of the Trust Fund consisting of the Grantor Trust maintains its status as a grantor trust under federal income tax law and not be treated as part of the Trust REMICs.
Creation of the Grantor Trust. The portion of the Trust Fund consisting of the Excess Liquidation Proceeds Option with respect to the Trust Loan, the related proceeds and the related distribution account shall be treated as a “grantor trust” (the “Grantor Trust”) for U.S. federal income tax purposes, and the Class ELP Certificates will represent undivided beneficial ownership interests in the Grantor Trust. As provided herein, the Certificate Administrator shall take all actions expressly required hereunder to ensure that the portion of the Trust Fund consisting of the Grantor Trust maintains its status as a grantor trust under federal income tax law and not be treated as part of the Trust REMICs.
Creation of the Grantor Trust. Concurrently with the assignment to the Trustee of the Excess Interest, and in exchange therefor and the establishment of the Excess Interest Distribution Account, the Trustee, pursuant to the written request of the Depositor executed by an officer of the Depositor, has executed, as Certificate Registrar, authenticated, as Authenticating Agent and delivered to or upon the order of the Depositor, the Class Z Certificates. The Class Z Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of Excess Interest and the Excess Interest Distribution Account and proceeds thereof, which portion shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code.
Creation of the Grantor Trust. Concurrently with the assignment to the Trustee of the Excess Interest, and in exchange therefor and the establishment of the Excess Interest Distribution Account, the Certificate Administrator, pursuant to the written request of the Depositor executed by an officer of the Depositor, has executed, as Certificate Registrar, authenticated, as Authenticating Agent and delivered to or upon the order of the Depositor, the Class NR Certificates. The Class NR Certificates, exclusive of the portion thereof representing a “regular interest” in the Upper-Tier REMIC, are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of Excess Interest and the Excess Interest Distribution Account and proceeds thereof, and the Class A-4FX Certificates and Class A-4FL Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of the Class A-4FX Specific Grantor Trust Assets and the Class A-4FL Specific Grantor Trust Assets, respectively, which portions shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code.
Creation of the Grantor Trust. The portions of the Trust consisting of the Class S Specific Grantor Trust Assets, undivided beneficial ownership of which will be represented by the Class S Certificates, shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code.