Foreign Tax Matters. The Seller Interests have not and have never been United States real property interests as defined in Section 897(g) of the Code and the regulations thereunder.
Foreign Tax Matters. Company does not have a permanent establishment in any foreign country, as defined in any applicable Tax treaty or convention between the United States of America and such foreign country. Company has not participated in an international boycott as defined in Section 999 of the Code.
Foreign Tax Matters. Remainco shall, at its own expense, have exclusive responsibility and control of the Remainco Foreign Tax Matter and the New News Corporation Foreign Tax Matter. The Parties shall assist and cooperate with each other during the course of any such examination, audit or litigation. Remainco shall reimburse New News Corporation for all reasonable out-of-pocket costs and expenses incurred by the New News Corporation Group that directly relate to the Remainco Foreign Tax Matter and the New News Corporation Foreign Tax Matter within thirty (30) Business Days of receiving an invoice from New News Corporation therefor, including a calculation of the amount of costs or expenses that provides sufficient detail to permit Remainco to reasonably understand the calculations.
Foreign Tax Matters. The Company is not and has never been a United States real property holding corporation as defined in Section 897(c)(2) of the Code.
Foreign Tax Matters. Each Lender which is a foreign person (i.e., a Person other than a United States Person for United States Federal income tax purposes) hereby agrees that:
Foreign Tax Matters. Neither Target nor any Subsidiary organized outside of the United States is or has been classified as a passive foreign investment company, as defined in Section 1297 of the Code.
Foreign Tax Matters. The Non-Released Party Trustee shall duly comply on a timely basis with all obligations, and satisfy all liabilities, imposed on the Non-Released Party Trustee or the Non-Released Party Trust under non-United States law relating to taxes. The Non-Released Party Trustee, or any other legal representative of the Non-Released Party Trust, shall not distribute the Non-Released Party Trust Assets or proceeds thereof without having first obtained all certificates required to have been obtained under applicable non-United States law relating to taxes.
Foreign Tax Matters. The Company and Parent: (i) do not have a permanent establishment (within the meaning of the applicable Tax treaty) and do not otherwise have an office or fixed place of business in a country outside the United States; (ii) are not engaged in a trade or business in any country other than the United States that subjected them to Tax in such country; (iii) are not, and have never been, subject to Tax in a jurisdiction outside the United States; and (iv) have not participated in an international boycott, as defined in Section 999 of the Code. The Company and Parent are not a party to any transaction or Contract that is in material conflict with the Tax rules on transfer pricing in any relevant jurisdiction.
Foreign Tax Matters. Seller is not and has never been either (i) a United States real property holding corporation as defined in Section 897(c)(2) of the Code, or (ii) a foreign person as defined in Section 1445(f)(3) of the Code.
Foreign Tax Matters. Except as set forth on Schedule 3.6(k), the Company does not have a permanent establishment in any foreign country, as defined in any applicable Tax treaty or convention between the United States and such foreign country. Except as set forth on Schedule 3.6(k), none of the Subsidiaries is an entity that is disregarded for U.S. federal income tax purposes. The Company has not participated in an international boycott, as defined in Section 999 of the Code.