Common use of Real Property Holding Corporation Status Clause in Contracts

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. 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. Since its date of ---------------------------------------- incorporation, the Company has not been, and as of the date of the Closing shall not bethis Agreement is not, a "United States real property holding corporation", ," as defined in Section 897(c)(2) of the CodeIRC, 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 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 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", Real Property Holding Corporation," as defined in Section 897(c)(2) of the Code, 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 it to become a "United States real property holding companyReal Property Holding Company," and the Company has filed with the Internal Revenue Service IRS all statements, if any, with its United States income tax Tax returns which are required under Section 1.897-2(h) of the Treasury 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 bethis Agreement is not, a "United States real property holding corporation", ," as defined in Section 897(c)(2) of the CodeIRC, 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 companycorporation," and the Company has filed with the Internal Revenue Service 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 its date of incorporation, the Company has Transaction Parties have 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 Transaction Parties have no current plans or intentions which would cause any of the Company Transaction Parties to become a "“United States real property holding company," ” and each of the Company Transaction Parties 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. Since its date of incorporationorganization, the Company has not been, and as of the date of the Closing shall not beis not, a "“United States real property holding corporation", ,” as defined in Section 897(c)(2) of the CodeIRC, 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 Company, has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns Tax Returns which are required under Section 1.897-2(h) of the Treasury Regulations.