Real Property Holding Corporation. The Company is not a United --------------------------------- States real property holding corporation within the meaning of Internal Revenue Code Section 897(c)(2) and any regulations promulgated thereunder.
Appears in 9 contracts
Samples: Series D Preferred Stock Purchase Agreement (Avantgo Inc), Series B Preferred Stock Purchase Agreement (Avantgo Inc), Series C Preferred Stock Purchase Agreement (Avantgo Inc)
Real Property Holding Corporation. The Company is not a "United --------------------------------- States real property holding corporation corporation" within the meaning of Internal Revenue Code Section 897(c)(2847(c)(2) and any regulations promulgated thereunderof the Code.
Appears in 4 contracts
Samples: Share Purchase Agreement (El Sitio Inc), Share Purchase Agreement (El Sitio Inc), Stock Purchase Agreement (El Sitio Inc)
Real Property Holding Corporation. The Company is not and has not been a United --------------------------------- States real property holding corporation within the meaning of Internal Revenue Code Section 897(c)(2) and any regulations promulgated thereunder), during the applicable period specified in Code Section 897(c)(1)(A)(ii).
Appears in 4 contracts
Samples: Merger Agreement (Leukosite Inc), Merger Agreement (Uromed Corp), Merger Agreement (Leukosite Inc)
Real Property Holding Corporation. The Neither the Company nor any of its subsidiaries is not a United --------------------------------- States real property holding corporation within the meaning of Internal Revenue Code Section 897(c)(2) and any regulations Section 1.897-2(c) of the Treasury Regulations promulgated thereunder.
Appears in 4 contracts
Samples: Preferred Stock and Warrant Purchase Agreement (Bizness Online Com), Preferred Stock and Warrant Purchase Agreement (MCG Finance Corp), Stock Purchase Agreement (Arch Communications Group Inc /De/)
Real Property Holding Corporation. The Company is not a "United --------------------------------- States real property holding corporation corporation" within the meaning of Internal Revenue Code Section 897(c)(2) and any regulations promulgated thereunderof the Code.
Appears in 3 contracts
Samples: Merger Agreement (Invitrogen Corp), Stock Purchase Agreement (Vista Information Solutions Inc), Stock Purchase Agreement (Vista Information Solutions Inc)
Real Property Holding Corporation. The Company is not a United --------------------------------- ------------------------------------ States real property holding corporation within the meaning of Internal Revenue Code Section 897(c)(2) and any regulations Section 1.897-2(c) of the Treasury Regulations promulgated thereunder.
Appears in 2 contracts
Samples: Securities Purchase Agreement (Pointe Communications Corp), Securities Purchase Agreement (Pointe Communications Corp)
Real Property Holding Corporation. The Company is not a United --------------------------------- States "real property holding corporation corporation" within the meaning of Section 897(c)(2) of the United States Internal Revenue Code Section 897(c)(2) and any regulations promulgated thereunderof 1986, as amended.
Appears in 2 contracts
Samples: Series F Preferred Stock Purchase Agreement (Mitokor), Preferred Stock Purchase Agreement (Mitokor)
Real Property Holding Corporation. The Company is not a United --------------------------------- States real property holding corporation within the meaning of Internal Revenue Code Section 897(c)(2) and any regulations Section 1.897-2(c) of the Regulations promulgated thereunder.
Appears in 1 contract
Samples: Series B Preferred Stock Purchase Agreement (Tenfold Corp /Ut)
Real Property Holding Corporation. The Company is not a "United --------------------------------- States real property holding corporation corporation" within the meaning of Internal Revenue Code Section section 897(c)(2) and any regulations promulgated thereunder.
Appears in 1 contract
Samples: Series B Preferred Stock Purchase Agreement (Virtual Telecom Inc)
Real Property Holding Corporation. The Company is not a United --------------------------------- States real property holding corporation within the meaning of Internal Revenue Code Section 897(c)(2) and any nay regulations promulgated thereunder.
Appears in 1 contract
Samples: Series C Preferred Stock Purchase Agreement (Air South Airlines Inc)
Real Property Holding Corporation. The Company is not a "United --------------------------------- States real property holding corporation within the meaning of Internal Revenue Code Section corporation" as defined in section 897(c)(2) of the Code and any regulations promulgated thereunderTreasury Regulation section 1.897-2(b).
Appears in 1 contract
Samples: Series a Preferred Stock Purchase Agreement (Encore Medical Corp)
Real Property Holding Corporation. The Company is not a "United --------------------------------- States real property holding corporation within corporation", as defined in Section 897(c)(2) of the meaning of U.S. Internal Revenue Code and Section 897(c)(21.897-2(b) and any regulations of the Regulations promulgated thereunderby the Internal Revenue Service.
Appears in 1 contract
Samples: Preferred Share Purchase Agreement (Given Imaging LTD)
Real Property Holding Corporation. The Company is not a United --------------------------------- States real property holding corporation within the meaning of the Internal Revenue Code Section 897(c)(2) and any regulations promulgated thereunder.
Appears in 1 contract
Samples: Series C Redeemable Preferred Stock Purchase Agreement (Bamboo Com Inc)
Real Property Holding Corporation. The Company is not a United --------------------------------- States real property holding corporation within the meaning of Internal Revenue Code Section 897(c)(2) of the Code and any regulations regulation promulgated thereunder.
Appears in 1 contract
Samples: Series C Preferred Stock Purchase Agreement (Ibasis Inc)
Real Property Holding Corporation. The Company is not a "United --------------------------------- States real property holding corporation corporation" within the meaning of Internal Revenue Code Section section 897(c)(2) and any regulations promulgated thereunder.
Appears in 1 contract
Samples: Agreement and Plan of Reorganization (Magma Design Automation Inc)