Subsidiaries of STH. All STH Subsidiaries which were taxed for federal income tax purposes as "S" corporations at the time of their acquisition by STH were taxed as "S" corporations from their respective dates of formation and had no current or accumulated earnings and profits for federal income tax purposes prior to their acquisition by STH.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Humphrey Hospitality Trust Inc), Agreement and Plan of Merger (Supertel Hospitality Inc)
Subsidiaries of STH. All subsidiaries of STH Subsidiaries which were taxed for federal income tax purposes as "S" corporations at the time of their acquisition by STH were taxed as "S" corporations from their respective dates of formation and had no current or accumulated earnings and profits for federal income tax purposes prior to their acquisition by STH.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (PMC Commercial Trust /Tx), Agreement and Plan of Merger (Supertel Hospitality Inc)
