Each of Borrower, Equity Owner, Mortgage Borrower or Operating Lessee Pledgor is a disregarded entity for U.S. federal income tax purposes and does not pay U.S. federal income tax at the entity level. Operating Lessee is subject to U.S. federal income tax. Each of Borrower, Equity Owner, Mortgage Borrower, Operating Lessee Pledgor and Operating Lessee has timely filed or caused to be filed all U.S. federal and other material tax returns and reports required to have been filed by it and has timely paid or caused to be paid all U.S. federal and other material Impositions required to have been paid by it, except for (a) any such Impositions that are being contested in good faith by appropriate proceedings and for which Borrower, Equity Owner, Mortgage Borrower, Operating Lessee Pledgor or Operating Lessee (as applicable) has set aside on its books adequate reserves in accordance with GAAP, and (b) Taxes and Other Charges, the payment of which shall be governed by Section 5.1.2 hereof and Section 7.2 of the Mortgage Loan Agreement.