Common use of Number of Beneficial Owners Clause in Contracts

Number of Beneficial Owners. The Transferee has no more than 50 beneficial owners for U.S. federal income tax purposes. For purposes of determining the total number of beneficial owners of the Transferee for such purposes, a beneficial owner of an interest in a partnership, grantor trust or S corporation for U.S. federal income tax purposes (each, a “Flow-Through Entity”) that owns, directly or through other Flow-Through Entities, an interest in the Transferee, is treated as a beneficial owner of the Transferee if more than 50% of the value of the beneficial owner's interest (directly or indirectly) in the Flow-Through Entity is attributed to the Flow-Through Entity’s interest in the Transferee.