Common use of Real Property Holding Corporation Status Clause in Contracts

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. Since its date of incorporation, neither the Company nor any of its Subsidiaries has been, and as of the date of the Closing or Additional Closing, as the case may be, 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.