Not a Foreign Person. Borrower (or if 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 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, or Borrower’s regarded owner if Borrower (or if such entity is a disregarded entity for U.S. federal income tax purposesentity, 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 (Retail Value Inc.), Loan Agreement (Retail Value Inc.), Loan Agreement (DDR Corp)
Not a Foreign Person. Borrower (or if such entity Borrower is a disregarded entity for U.S. federal income tax purposes, such entity’s its regarded beneficial owner) is not a “foreign person” within the meaning of Section 1445(f)(3) of the Code.
Appears in 2 contracts
Samples: Loan Agreement (VICI Properties L.P.), Loan Agreement (MGM Growth Properties Operating Partnership LP)
Not a Foreign Person. Borrower (or and, if such entity Borrower is a disregarded entity for U.S. federal income tax purposes, such entity’s beneficial owner) the Person treated as owning the assets owned by Borrower for federal income tax purposes, is not a “foreign person” within the meaning of Section §1445(f)(3) or of §7701 of the 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. Neither Borrower nor Operating Lessee (or if such entity any of Borrower or Operating Lessee 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 Code.
Appears in 1 contract
Not a Foreign Person. No Borrower (or nor if such entity is treated as a disregarded entity for U.S. federal income tax purposes, such entity’s beneficial its regarded owner) is not a “foreign person” within the meaning of Section § 1445(f)(3) of the IRS Code.
Appears in 1 contract
Not a Foreign Person. No Individual Borrower or Individual Operating Lessee (or if 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 Code.
Appears in 1 contract
Not a Foreign Person. Neither Borrower nor Operating Lessee (or if 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 Code.
Appears in 1 contract
Not a Foreign Person. The Borrower (or if such entity is or, for so long as the Borrower remains a “disregarded entity entity” for U.S. federal income tax purposes, the entity treated as the regarded owner for such entity’s beneficial ownerpurposes) is not a “foreign person” within the meaning of Section 1445(f)(3) of the Internal Revenue Code.
Appears in 1 contract
Samples: Loan Agreement (Brookfield DTLA Fund Office Trust Investor Inc.)
Not a Foreign Person. Borrower (or if 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 Code.
Appears in 1 contract
