Tax Classification. The MAC Pool will be classified as a grantor trust under subpart E, part I of subchapter J of the Code, and the MAC Notes will represent beneficial ownership of interests in the Exchangeable Notes for U.S. federal income tax purposes.
Appears in 13 contracts
Sources: Exchange Administration Agreement, Exchange Administration Agreement, Exchange Administration Agreement
Tax Classification. The MAC Pool will be classified as a grantor trust under subpart E, part I of subchapter J of the Code, and the MAC Notes will represent beneficial ownership of interests in the Exchangeable Class M Notes for U.S. federal income tax purposes.
Appears in 10 contracts
Sources: Exchange Administration Agreement, Exchange Administration Agreement, Exchange Administration Agreement
Tax Classification. The MAC Pool will be classified as a grantor trust under subpart E, part I of subchapter J of the Code, and the MAC Notes will represent beneficial ownership of interests in the Exchangeable Original Notes for U.S. federal income tax purposes.
Appears in 4 contracts
Sources: Exchange Administration Agreement, Exchange Administration Agreement, Exchange Administration Agreement