Code Section 897 Company. Seagate is not and has not been during the period referred to in section 897(c)(1)(A)(ii) a United States real property holding corporation within the meaning of section 897(c)(2) of the Code.
Appears in 4 contracts
Samples: Merger Agreement (Veritas Software Corp /De/), Agreement and Plan of Merger and Reorganization (Seagate Technology Holdings), Merger Agreement (Seagate Technology Malaysia Holding Co Cayman Islands)