Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, and the arrangement hereby be maintained, in a manner consistent with rules applicable to a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 338 contracts
Sources: Agreement Between Noteholders (BBCMS Mortgage Trust 2025-5c38), Agreement Between Noteholders (BBCMS Mortgage Trust 2025-5c38), Agreement Between Noteholders (BBCMS Mortgage Trust 2025-5c38)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 324 contracts
Sources: Agreement Between Noteholders (Wells Fargo Commercial Mortgage Trust 2025-5c6), Agreement Between Noteholders (Bank5 2025-5yr16), Agreement Between Noteholders (Bank 2025-Bnk49)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will shall not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 78 contracts
Sources: Co Lender Agreement (BMO 2025-5c12 Mortgage Trust), Co Lender Agreement (Morgan Stanley Bank of America Merrill Lynch Trust 2025-C35), Co Lender Agreement (Morgan Stanley Bank of America Merrill Lynch Trust 2025-C35)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, and the arrangement hereby be maintained, in a manner consistent with rules applicable to a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among between the parties.
Appears in 71 contracts
Sources: Agreement Between Noteholders (Bank5 2024-5yr10), Agreement Between Noteholders (Bank5 2024-5yr10), Agreement Between Noteholders (Benchmark 2024-V10 Mortgage Trust)
Statement of Intent. The Agent and each Noteholder Holder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to a grantor trust under subpart Esubtitle A, chapter 1, subchapter J, part I of subchapter J of chapter 1 I, subpart E of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 43 contracts
Sources: Co Lender Agreement (BBCMS Mortgage Trust 2025-5c38), Co Lender Agreement (Wells Fargo Commercial Mortgage Trust 2025-C65), Co Lender Agreement (BMO 2025-C13 Mortgage Trust)
Statement of Intent. The Agent and each Noteholder Initial Note Holder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 36 contracts
Sources: Agreement Between Noteholders (Morgan Stanley Bank of America Merrill Lynch Trust 2025-5c2), Agreement Between Noteholders (BBCMS Mortgage Trust 2022-C15), Agreement Between Noteholders (BBCMS Mortgage Trust 2022-C15)
Statement of Intent. The Agent and each Noteholder Note Holder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 35 contracts
Sources: Agreement Between Note Holders (BMO 2025-5c12 Mortgage Trust), Agreement Between Note Holders (Benchmark 2025-B41 Mortgage Trust), Agreement Between Note Holders (Benchmark 2025-B41 Mortgage Trust)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to a grantor trust under subpart Esubtitle A, chapter 1, subchapter J, part I of subchapter J of chapter 1 I, subpart E of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 24 contracts
Sources: Co Lender Agreement (BMO 2023-C4 Mortgage Trust), Co Lender Agreement (BBCMS Mortgage Trust 2022-C18), Co Lender Agreement (BBCMS Mortgage Trust 2020-C7)
Statement of Intent. The Agent and each Noteholder Note Holder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will shall not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 18 contracts
Sources: Co Lender Agreement (BBCMS Mortgage Trust 2025-5c38), Co Lender Agreement (Morgan Stanley Bank of America Merrill Lynch Trust 2025-5c2), Co Lender Agreement (Wells Fargo Commercial Mortgage Trust 2025-5c6)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment invest trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will shall not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 4 contracts
Sources: Co Lender Agreement (CF 2019-Cf3 Mortgage Trust), Co Lender Agreement (Morgan Stanley Capital I Trust 2019-L3), Co Lender Agreement (GS Mortgage Securities Trust 2019-Gsa1)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, and the arrangement hereby be maintained, in a manner consistent with rules applicable to a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §§ 301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 4 contracts
Sources: Co Lender Agreement (BBCMS Mortgage Trust 2022-C15), Co Lender Agreement (Benchmark 2022-B33 Mortgage Trust), Co Lender Agreement (BBCMS Mortgage Trust 2022-C14)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c301.7701‑4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 3 contracts
Sources: Noteholders Agreement (3650R 2022-Pf2 Commercial Mortgage Trust), Agreement Between Noteholders (Wells Fargo Commercial Mortgage Trust 2018-C45), Agreement Between Noteholders (Citigroup Commercial Mortgage Trust 2018-C5)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §§ 301.7701-4(c), and the parties will shall not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 2 contracts
Sources: Co Lender Agreement (GS Mortgage Securities Trust 2020-Gsa2), Co Lender Agreement (BBCMS Mortgage Trust 2020-C8)
Statement of Intent. The Agent and each Noteholder intend that the Notes Note Groups be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 2 contracts
Sources: Co Lender Agreement (CSAIL 2015-C3 Commercial Mortgage Trust), Co Lender Agreement (CSAIL 2015-C3 Commercial Mortgage Trust)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among between the parties.
Appears in 2 contracts
Sources: Agreement Between Noteholders (BBCMS Mortgage Trust 2019-C3), Agreement Between Noteholders (Wells Fargo Commercial Mortgage Trust 2019-C50)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will shall not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 1 contract
Sources: Co Lender Agreement (GS Mortgage Securities Trust 2019-Gsa1)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to a grantor trust under subpart Esubtitle A, chapter 1, subchapter J, part I of subchapter J of chapter 1 I, subpart E of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-301.7701- 4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 1 contract
Sources: Co Lender Agreement (Benchmark 2019-B12 Mortgage Trust)
Statement of Intent. The Agent and each Noteholder Initial Note Holder intend that the Notes be classified, classified and the arrangement hereby be maintained, in a manner consistent with rules applicable to maintained as a grantor trust under subpart E, part I of subchapter J of chapter 1 of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “"taxable mortgage pool” " or association taxable as a corporation among the parties.
Appears in 1 contract
Sources: Agreement Between Noteholders (BMO 2022-C2 Mortgage Trust)
Statement of Intent. The Agent and each Noteholder intend that the Notes be classified, classified and the arrangement hereby be maintained, maintained in a manner consistent with the rules applicable to a grantor trust under subpart Esubtitle A, chapter 1, subchapter J, part I of subchapter J of chapter 1 I, subpart E of the Code that is a fixed investment trust within the meaning of Treasury Regulation §301.7701-4(c), and the parties will not take any action inconsistent with such classification. It is neither the purpose nor the intent of this Agreement to create a partnership, joint venture, “taxable mortgage pool” or association taxable as a corporation among the parties.
Appears in 1 contract
Sources: Co Lender Agreement (UBS Commercial Mortgage Trust 2017-C2)