No Target Entity Sample Clauses
No Target Entity. (i) has constituted either a “distributing corporation” or a “controlled corporation” (within the meaning of Section 355(a)(1)(A) of the Code) in a distribution of securities (to any Person or entity that is not a member of the consolidated group of which the Company is the common parent corporation) qualifying for, or intended to qualify for, Tax-free treatment under Section 355 of the Code (A) within the two-year period ending on the date hereof or (B) in a distribution which could otherwise constitute part of a “plan” or “series of related transactions” (within the meaning of Section 355(e) of the Code) in conjunction with the transactions contemplated by this Agreement; or (ii) is or has ever been (A) a U.S. real property holding corporation within the meaning of Section 897(c)(2) of the Code, or (B) a member of any consolidated, combined, unitary or affiliated group of corporations for any Tax purposes other than a group of which the Company is or was the common parent corporation.
No Target Entity. (1) is the holder or beneficial owner of any shares or other capital in any body corporate (wherever incorporated) except as described in Schedule 8; or
(2) is a member of any partnership or other unincorporated association (other than a recognised trade association).
No Target Entity. (1) is a member of any partnership, joint venture, consortium or unincorporated association; (2) participates, or is a party to any arrangement that may give rise to participation, in any business or profit sharing commissions or other income, other than with another Target Entity; and (3) is the trustee of a trust.