Not a Foreign Person. Borrower, or Borrower’s regarded owner if Borrower is a disregarded entity, is not a “foreign person” within the meaning of § 1445(f)(3) of the IRS Code.
Appears in 4 contracts
Samples: Loan Agreement (Retail Value Inc.), Loan Agreement (Retail Value Inc.), Loan Agreement (Retail Value Inc.)
Not a Foreign Person. Borrower, Borrower (or Borrower’s regarded owner if Borrower such entity is a disregarded entity for U.S. federal income tax purposes, such entity, ’s beneficial owner) is not a “foreign person” within the meaning of § Section 1445(f)(3) of the IRS Code.
Appears in 3 contracts
Samples: Loan Agreement (Apartment Income REIT, L.P.), Loan Agreement (Apartment Income REIT, L.P.), Loan Agreement (Apartment Income REIT, L.P.)
Not a Foreign Person. Borrower, Borrower (or Borrower’s regarded owner if Borrower is a disregarded entityentity for U.S. federal income tax purposes, its regarded beneficial owner) is not a “foreign person” within the meaning of § Section 1445(f)(3) of the IRS Code.
Appears in 2 contracts
Samples: Loan Agreement (VICI Properties L.P.), Loan Agreement (MGM Growth Properties Operating Partnership LP)
Not a Foreign Person. BorrowerBorrower and, or Borrower’s regarded owner if Borrower is a disregarded entityentity for federal income tax purposes, the Person treated as owning the assets owned by Borrower for federal income tax purposes, is not a “foreign person” within the meaning of § §1445(f)(3) or of §7701 of the IRS Code.
Appears in 2 contracts
Samples: Loan Agreement (Lightstone Value Plus Real Estate Investment Trust V, Inc.), Building Loan Agreement (KBS Strategic Opportunity REIT, Inc.)
Not a Foreign Person. Borrower, or BorrowerXxxxxxxx’s regarded owner if Borrower Xxxxxxxx is a disregarded entity, is not a “foreign person” within the meaning of § 1445(f)(3of§ 1445(£)(3) of the IRS Code.
Appears in 1 contract
Samples: Loan Agreement (SITE Centers Corp.)
Not a Foreign Person. BorrowerThe Borrower (or, or Borrower’s for so long as the Borrower remains a “disregarded entity” for U.S. federal income tax purposes, the entity treated as the regarded owner if Borrower is a disregarded entity, for such purposes) is not a “foreign person” within the meaning of § Section 1445(f)(3) of the IRS Internal Revenue Code.
Appears in 1 contract
Samples: Loan Agreement (Brookfield DTLA Fund Office Trust Investor Inc.)
Not a Foreign Person. Borrower, or Borrower’s regarded owner No Borrower (nor if Borrower is treated as a disregarded entityentity for U.S. federal income tax purposes, its regarded owner) is not a “foreign person” within the meaning of § 1445(f)(3) of the IRS Code.
Appears in 1 contract
Not a Foreign Person. Borrower, Borrower (or Borrower’s regarded owner if Borrower such entity is a disregarded entity for U.S. federal income tax purposes, such entity, ’s beneficial owner) is not a “foreign person” within the meaning of § 1445(f)(3) of the IRS Code.
Appears in 1 contract
