Real Property Holding Corporation Status. Since its inception the Company has not been a "United States real property holding corporation", as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended, and in Section 1.897- 2(b) of the Treasury Regulations issued thereunder (the "Regulations"), and the Company has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Regulations.
Real Property Holding Corporation Status. Since its date of incorporation, the Company has not been, and as of the date of the Closing shall not be, a "United States real property holding corporation", as defined in Section 897(c)(2) of the Code, and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a "United States real property holding company," and the Company has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Real Property Holding Corporation Status. Asymetrix and each Merger ---------------------------------------- Sub is not and has at no time been a "United States real property holding corporation" within the meaning of Section 897(c) of the Code.
Real Property Holding Corporation Status. Since January 1, 2003, the Company has not been a "United States real property holding corporation", as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended, and in Section 1.897-2(b) of the Treasury Regulations issued thereunder (the "REGULATIONS"), and the Company has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Regulations.
Real Property Holding Corporation Status. Since its date of incorporation, neither the Company nor any of its Subsidiaries has been, and as of the date of the Closing, shall not be, a "United States real property holding corporation," as defined in Section 897(c)(2) of the Internal Revenue Code, and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. Neither the Company nor any of its Subsidiaries have any current plans or intentions which would cause the Company or any of its Subsidiaries to become a "United States real property holding corporation," and the Company and each of its Subsidiaries have filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Real Property Holding Corporation Status. The Company has not been a United States real property holding corporation within the meaning of Code Section 897(c)(2) during the applicable period described in Code Section 897(c)(1)(A)(ii).
Real Property Holding Corporation Status. The Company is a United States real property holding corporation within the meaning of Code Section 897(c)(2) during the applicable period described in Code Section 897(c)(1)(A)(ii) and its common stock is traded on the Electronic Over-the-Counter Bulletin Board.
Real Property Holding Corporation Status. Since its date of ---------------------------------------- incorporation, the Company has not been, and as of the date of the Closing shall not be, a "United States real property holding corporation", as defined in Section 897(c)(2) of the IRC, and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become (and shall use reasonable efforts consistent with sound business practice to avoid becoming) a "United States real property holding company," and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Real Property Holding Corporation Status. Since their respective dates of incorporation (and that of their earliest predecessor) neither the Company nor MCI has been a "United States real property holding corporation", as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the "Code"), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder (the "Regulations").
Real Property Holding Corporation Status. In connection with the purchase of units of WLTR Holdings, LLC, a Delaware limited liability company (the “Company”), pursuant to the Stock Purchase Agreement and Agreement and Plan of Merger (the “Agreement”), dated as of [---], 2022, by and among the Company, TELUS International Holding (U.S.A.) Corp. (“Buyer”), and certain other parties thereto, Bxxxx has requested a statement from the Company pursuant to Treas. Reg. § 1.1445-11T(d)(2) certifying that an interest in the Company is not an interest in property described therein. Therefore, the Company states to Buyer as follows:
