Certificate of Non-Foreign Status. In order to comply with § 1445 of the Code and the applicable Treasury Regulations thereunder, in the event of the disposition by the Company of a United States real property interest as defined in the Code and Treasury Regulations, each Member shall provide to the Company an affidavit stating, under penalties of perjury, (i) the Member’s address, (ii) United States taxpayer identification number, and (iii) that the Member is not a foreign person as that term is defined in the Code and Treasury Regulations. Failure by any Member to provide such affidavit by the date of such disposition shall authorize the Manager to withhold ten percent (10%) of each such Member’s distributive share of the amount realized by the Company on the disposition.
Certificate of Non-Foreign Status. One (1) original of the Certificate of Non-Foreign Status, duly executed and acknowledged by Seller.
Certificate of Non-Foreign Status. Section 1445 of the Internal Revenue Code of 1986, as amended (the “Code”), provides that under specified circumstances, a transferee of a United States real property interest must withhold tax if the transferor is a foreign person. For United States tax purposes (including Section 1445), the owner of a disregarded entity (which has legal title to a United States real property interest under local law) will be the transferor of the real property interest and not the disregarded entity. To inform (the “Transferee”), that withholding of tax is not required upon the disposition of a United States real property interest by (the “Transferor”), the undersigned hereby certifies the following:
Certificate of Non-Foreign Status. The undersigned, being duly sworn, hereby deposes, certifies and states on oath as follows:
Certificate of Non-Foreign Status. A certificate addressed to Buyer made in compliance with Paragraph 1445 of the Internal Revenue Code that Seller is not a foreign person and not subject to withholding requirements.
Certificate of Non-Foreign Status. Section 1445 of the Internal Revenue Code provides that a transferee of a U.S. real property interest must withhold tax if the transferor is a foreign person. To inform _________________________ (“Transferee”), that withholding of tax is not required upon the disposition of a U.S. real property interest by [Xxxx X. Xxxxxxxxxxxxx] [Xxxxx Xxxxxxx] (“Transferor”), the undersigned hereby certifies to Transferee the following:
Certificate of Non-Foreign Status. A certificate of non-foreign status for Seller (and/or the relevant DCT Affiliate) sworn to by Seller (and/or the relevant DCT Affiliate); and
Certificate of Non-Foreign Status. Prior to the Close of Escrow, Seller shall execute and deposit into Escrow a Certificate of Non- Foreign Status certifying that Seller is a non-foreign person in the form attached hereto as Exhibit D and incorporated herein ("Certificate of Non- Foreign Status"); 3.3.2 Grant Xxxxx, Xxxx of Sale and Assignment of Leases. Prior to the Close of Escrow, Seller shall execute, acknowledge and deposit into Escrow Grant Deed(s) in the form attached hereto as Exhibit E; and 3.3.3
Certificate of Non-Foreign Status. Section 1445 of the Internal Revenue Code of 1986, as amended, provides that a transferee of a U.S. real property interest must withhold tax if the transferor is a foreign person. For U.S. federal income tax purposes (including Section 1445), the owner of a disregarded entity (which has legal title to a U.S. real property interest under local law) will be the transferor of the property and not the disregarded entity. To inform the transferee that withholding of tax is not required upon the disposition of a U.S. real property interest by HOSPITALITY PROPERTIES TRUST, a Maryland real estate investment trust (“Transferor”), pursuant to that certain First Transaction Agreement, dated as of January 16, 2019, among Transferor, HPT TA Properties Trust, HPT TA Properties LLC, HPT PSC Properties Trust, HPT PSC Properties LLC, TravelCenters of America LLC, TravelCenters of America Holdings Company LLC and TA Operating LLC, Transferor hereby certifies to TA Operating LLC (“Transferee”) the following:
Certificate of Non-Foreign Status. Each Operating Company shall deliver to Buyer a certificate of non-foreign status as provided for in Treasury Regulations section 1.1445-2(b)(2).
