FIRPTA Status. None of the Sellers is a “foreign person” as defined in the Foreign Investment in Real Property Tax Act, 26 U.S.C. 1445(f)(3) (“FIRPTA”), and Sellers agrees to execute and deliver to Purchaser an affidavit to that effect, including each Seller’s federal tax identification number, at or before the Closing.
FIRPTA Status. The Company covenants and agrees that it will take all reasonable steps within its control necessary to ensure that it will not become a “United States real property holding corporation” within the meaning of Section 897(c)(2) of the Code.
FIRPTA Status. Xxxxx is not, and has not been at any time during ------------- the five year period preceding the date hereof, a "United States real property holding corporation" as defined in Section 897 of the Code and the regulations promulgated thereunder.
FIRPTA Status. Computone is not, and has not been at any time during the five year period preceding the date hereof, a "United States real property holding corporation" as defined in Section 897 of the Code and the regulations promulgated thereunder.
FIRPTA Status. Neither HC nor Newco is , and neither has at any ------------- time during the five year period preceding the date hereof been, a "United States real property holding corporation" as defined in Section 897 of the Code and the regulations promulgated thereunder.
FIRPTA Status. XLI is not, and has not been at any time during the five year period preceding the date hereof, a "United States real property holding corporation" as defined in Section 897 of the Code and the regulations promulgated thereunder.
FIRPTA Status. The Seller is not, and has not been at any time during the five-year period preceding the date hereof, a "United States real property holding corporation" as defined in Section 897 of the Internal Revenue Code of 1954, as amended, and the regulations promulgated thereunder.
FIRPTA Status. The Purchaser is not, and has not been at any time during the five year period preceding the date hereof, a "United States real property holding corporations as defined in Section 897 of the Internal Revenue Code of 1954, as amended, and the regulations promulgated thereunder.
FIRPTA Status. Georgia-Pacific is not a “foreign person” within the meaning of the Foreign Investment in Real Property Tax Act of 1986, the 1984 Tax Reform Act, or Section 1445 of the Internal Revenue Code and applicable regulations.
FIRPTA Status. Seller is not a “foreign person” as defined in the Foreign Investment in Real Property Tax Act, 26 U.S.C. 1445(f)(3) (“FIRPTA”), and Seller agrees to execute and deliver to Purchaser an affidavit to that effect, including Seller’s federal tax identification number, before the Closing.
