Common use of Signature on Returns; Tax Matters Partner Clause in Contracts

Signature on Returns; Tax Matters Partner. (a) The Certificateholder shall sign the tax returns of the Trust on behalf of the Trust; provided, that if there is more than one Certificateholder, the tax returns of the Trust shall be signed by the Certificateholder that is the “tax matters partner” of the Trust under Section 5.05(b). (b) For any period during which the beneficial interests of the Trust are held by more than one Person and the Trust is treated as a partnership for purposes of U.S. federal, state and local income or franchise tax, or any other tax measured in whole or in part by income, the Certificateholder holding Certificates evidencing the largest portion of the Certificates shall be designated the “tax matters partner” of the Trust pursuant to Section 6231(a)(7)(A) of the Code and applicable Treasury Regulations. If the Trust is treated as a partnership for tax purposes, (i) for any taxable period beginning before December 31, 2017, the “tax matters partner” of the Trust shall represent the Trust (at the Trust’s expense) in connection with all examinations of the Trust’s affairs by tax authorities, including resulting judicial and administrative proceedings, and shall expend the Trust funds for professional services and costs associated therewith and (ii) for any taxable period beginning after December 31, 2017, the “tax matters partner” shall be designated as the “partnership representative” within the meaning of Section 6223 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015) and the Trust will, to the extent practicable, make the election described in Section 6226 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015). Finally, the Trust will not elect to apply Sections 6221-6241 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015) to any taxable period of the Trust beginning before December 31, 2017.

Signature on Returns; Tax Matters Partner. (a) The Certificateholder In the event that the Issuer shall sign the be required to file federal or other income tax returns of the Trust on behalf of the Trust; providedas a partnership, that if there is more than one Certificateholder, the tax such returns of the Trust shall be signed by an authorized signatory for the Transferor, for as long as it is a holder of a Trust Certificate, and thereafter, the largest percentage holder of the Trust Certificate, or such other Person as shall be required by law to sign such returns of the Issuer. (b) By acceptance of its beneficial interest in a Trust Certificate, each Trust Certificateholder agrees that in the event that the Issuer is classified as a partnership for federal income tax purposes, the Transferor, for as long as it is a holder of a Trust Certificate, and thereafter, the largest percentage holder of the Trust Certificate, shall be the “tax matters partner” of the Trust under Section 5.05(b). (b) For any period during which Issuer pursuant to the beneficial interests of Code. If the Trust are held by more than one Person and the Trust Issuer is treated classified as a partnership for federal income tax purposes of U.S. federal, state and local income or franchise tax, or any other tax measured in whole or in part by income, the Certificateholder holding Certificates evidencing the largest portion of the Certificates shall be designated the “tax matters partner” of the Trust pursuant to Section 6231(a)(7)(A) of the Code and applicable Treasury Regulations. If the Trust is treated as a partnership for tax purposes, (i) for any taxable period beginning before December 31, 2017, the “tax matters partner” of the Trust shall represent the Trust (at the Trust’s expense) Issuer in connection with all examinations of the TrustIssuer’s affairs by tax authorities, including resulting judicial and administrative proceedings, and shall expend the Trust funds for professional services and costs associated therewith and (ii) for any taxable period beginning after December 31, 2017, the “tax matters partner” shall be designated as the “partnership representative” within the meaning of Section 6223 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015) and the Trust Issuer will, to the extent practicable, make the election described in Section 6226 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015). Finally, if the Trust Issuer is treated as a partnership for federal income tax purposes, the Issuer will not elect to apply Sections 6221-6241 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015) to any taxable period of the Trust Issuer beginning before December 31, 2017.

Signature on Returns; Tax Matters Partner. (a) The Certificateholder Owner Trustee shall sign sign, on behalf of the Issuer, all tax returns of the Trust on behalf of Issuer that are prepared and delivered to it for execution by the Trust; providedAdministrator, that if there is more than one Certificateholderunless Applicable Law requires a Certificateholder to sign such documents, the tax returns of the Trust in which case such documents shall be signed by the Depositor if the Depositor is a Certificateholder at the applicable time. To the extent that the Issuer is treated as a partnership, the Depositor shall be the “tax matters partner” of the Trust under Section 5.05(b). (b) For any period during which Issuer pursuant to the beneficial interests of Code if the Trust are held by more than one Person and Depositor is a Certificateholder at the Trust applicable time. If the Depositor is treated as not a partnership for purposes of U.S. federalCertificateholder at the applicable time, state and local income or franchise tax, or any other tax measured in whole or in part by income, the Certificateholder holding Certificates evidencing the largest portion of the Certificates shall be designated the “tax matters partner” of the Trust pursuant to Section 6231(a)(7)(A) Issuer shall be the partner with the largest Percentage Interest in the Issuer. Under no circumstances shall the Owner Trustee be the “tax matters partner” of the Code and applicable Treasury RegulationsIssuer. If the Trust Issuer is treated classified as a partnership for federal income tax purposes, purposes (i) for any taxable period beginning before December 31, 2017, the “tax matters partner” of the Trust shall represent the Trust (at the Trust’s expense) Issuer in connection with all examinations of the TrustIssuer’s affairs by tax authorities, including resulting judicial and administrative proceedings, and shall expend the Trust funds for professional services and costs associated therewith proceedings and (ii) for any taxable period beginning after December 31, 2017, the “tax matters partner” shall be designated as the “partnership representative” within the meaning of Section 6223 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015Act) and the Trust willAdministrator will cause the Issuer, to the extent practicable, to make the election described in Section 6226 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015Act). Finally, if the Trust Issuer is treated as a partnership for federal income tax purposes, the Issuer will not elect to apply Sections 6221-6241 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015Act) to any taxable period of the Trust Issuer beginning before December 31, 2017.

Signature on Returns; Tax Matters Partner. (a) The Certificateholder Owner Trustee shall sign sign, on behalf of the Issuer, all tax returns of the Trust on behalf of Issuer that are prepared and delivered to it for execution by the Trust; providedAdministrator, that if there is more than one Certificateholderunless Applicable Law requires a Certificateholder to sign such documents, the tax returns of the Trust in which case such documents shall be signed by the Depositor if the Depositor is a Certificateholder at the applicable time. To the extent that the Issuer is treated as a partnership, the Depositor shall be the “tax matters partner” of the Trust under Section 5.05(b). (b) For any period during which Issuer pursuant to the beneficial interests of Code if the Trust are held by more than one Person and Depositor is a Certificateholder at the Trust applicable time. If the Depositor is treated as not a partnership for purposes of U.S. federalCertificateholder at the applicable time, state and local income or franchise tax, or any other tax measured in whole or in part by income, the Certificateholder holding Certificates evidencing the largest portion of the Certificates shall be designated the “tax matters partner” of the Trust pursuant to Section 6231(a)(7)(A) Issuer shall be the partner with the largest Percentage Interest in the Issuer. Under no circumstances shall the Owner Trustee be the “tax matters partner” of the Code and applicable Treasury RegulationsIssuer. If the Trust Issuer is treated classified as a partnership for federal income tax purposes, purposes (i) for any taxable period beginning before December 31, 2017, the “tax matters partner” of the Trust shall represent the Trust (at the Trust’s expense) Issuer in connection with all examinations of the TrustIssuer’s affairs by tax authorities, including resulting judicial and administrative proceedings, and shall expend the Trust funds for professional services and costs associated therewith proceedings and (ii) for any taxable period beginning after December 31, 2017, the “tax matters partner” shall be designated as the “partnership representative” within the meaning of Section 6223 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015Act) and the Trust willAdministrator will cause the Issuer, to the extent practicable, to make the election described in Section 6226 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015Act). Finally, if the Trust Issuer is treated as a partnership for federal income tax purposes, the Issuer will not elect to apply Sections 6221-6241 of the Code (as amended by P.L. 114-74, the Bipartisan Budget Act of 2015Act) to any taxable period of the Trust Issuer beginning before December 31, 2017.