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.
Appears in 4 contracts
Samples: Common Stock Purchase Agreement (Intel Corp), Common Stock and Warrant Purchase Agreement (Intel Corp), Common Stock and Warrant Purchase Agreement (Intel Corp)
Real Property Holding Corporation Status. Since its inception 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 amendedCode, and in Section 1.897- 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.
Appears in 3 contracts
Samples: Series a Convertible Preferred Stock Purchase Agreement (Net Value Holdings Inc), Series a Convertible Preferred Stock Purchase Agreement (Net Value Holdings Inc), Preferred Stock Purchase Agreement (Net Value Holdings Inc)
Real Property Holding Corporation Status. Since its inception 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 amendedamended (the "Code"), and in Section 1.897- 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.
Appears in 2 contracts
Samples: Series a Preferred Stock Purchase Agreement (Chaparral Network Storage Inc), Series C Preferred Stock Purchase Agreement (Chaparral Network Storage Inc)
Real Property Holding Corporation Status. Since its inception 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 amendedIRC, and in Section 1.897- 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.
Appears in 1 contract
Samples: Series D Preferred Stock Purchase Agreement (Alladvantage Com Inc)
Real Property Holding Corporation Status. Since its inception incorporation, 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 Regulationsthereunder.
Appears in 1 contract
Samples: Series B Preferred Stock Purchase Agreement (Rhythms Net Connections Inc)
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- 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.
Appears in 1 contract
Samples: Common Stock Purchase Agreement (Exodus Communications Inc)
Real Property Holding Corporation Status. Since its inception inception, ---------------------------------------- the Company company has not been a "United States real property holding corporation", ," as defined in Section 897(c)(2) of the U.S. United States Internal Revenue Code of 1986, as amended, and in Section 1.897- 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.
Appears in 1 contract
Samples: Common Shares Purchase Agreement (Discreet Logic Inc)
Real Property Holding Corporation Status. The Company does not own any real property or any interests therein. 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. United States Internal Revenue Code of 1986, as amended(the “Code”), and in Section 1.897- 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.
Appears in 1 contract
Samples: Securities Purchase Agreement (PRB GasTransportation, Inc.)
Real Property Holding Corporation Status. Since its inception 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 amendedCode, and in Section 1.897- 1.897-2(b) of the Treasury Regulations issued thereunder (the "RegulationsREGULATIONS"), and the . The Company has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns which that are required under Section 1.897-2(h) of the Regulations.
Appears in 1 contract
Samples: Series B Preferred Stock and Common Stock Warrants Purchase Agreement (Loyaltypoint Inc)
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- 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 Regulationsthereunder.
Appears in 1 contract
Real Property Holding Corporation Status. Since its inception 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 amendedCode, and in Section 1.897- 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.
Appears in 1 contract
Samples: Series a Convertible Preferred Stock Purchase Agreement (Net Value Holdings Inc)
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- 1.897-2(b) of the Treasury Regulations issued thereunder (the "RegulationsREGULATIONS"), 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.
Appears in 1 contract
Samples: Series a Preferred Stock Purchase Agreement (Asymetrix Learning Systems Inc)
Real Property Holding Corporation Status. Since its inception date of incorporation 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- 1.897-2(b) of the U. S. 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 Regulationsthereunder.
Appears in 1 contract
Samples: Reclassification and Sale of Shares Agreement (Ulta Salon, Cosmetics & Fragrance, Inc.)
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- 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.
Appears in 1 contract
Samples: Series F Preferred Stock Purchase Agreement (Extricity Inc)
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- 1.897-2(b) of the Treasury Regulations issued thereunder (the "RegulationsREGULATIONS"), 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 1.897l.897-2(h) of the Regulations.
Appears in 1 contract
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- 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.
Appears in 1 contract
Real Property Holding Corporation Status. Since its inception 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 amendedCode, and in Section 1.897- 1.897-2(b) of the Treasury Regulations issued thereunder (the "Regulations"), and the . The Company has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns which that are required under Section 1.897-2(h) of the Regulations.
Appears in 1 contract
Samples: Series B Preferred Stock and Common Stock Warrants Purchase Agreement (Loyaltypoint Inc)
Real Property Holding Corporation Status. Since its inception 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 amendedCode, and in Section 1.897- 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 1.897-1.897- 2(h) of the Regulations.
Appears in 1 contract
Samples: Series a Convertible Preferred Stock Purchase Agreement (Net Value Holdings Inc)
