Pass-Through Entity. Since the date of its formation, the Company and each of its U.S. Subsidiaries has always been a “partnership” or a “disregarded entity” as such term is defined in Section 7701(a)(2) of the Code and has never been taxable as a “corporation” as such term is defined in Section 7701(a)(3) of the Code.
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Samples: Merger Agreement (Vmware, Inc.), Merger Agreement (Emc Corp)
Pass-Through Entity. Since the date of its formation, the Company and each of its U.S. Subsidiaries has always been a “partnership” or a “disregarded entity” as such term is defined in Section 7701(a)(2) of the Code and has never been taxable as a “corporation” as such term is defined in Section 7701(a)(3) of the Code.. 27 (n)
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Samples: Merger Agreement
Pass-Through Entity. Since the date of its formation, the Company and each of its U.S. Subsidiaries has always been taxable as a “partnership” or a “disregarded entity” as such term is defined in Section 7701(a)(2) of the Code and has never been taxable as a “corporation” as such term is defined in Section 7701(a)(3) of the Code.
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