Tax Certification. Parent shall have received a certification from the Company in the form prescribed by Treasury regulations under Section 1445 of the Code to the effect that the Company is not (and was not at any time during the five-year period ending on the Closing Date) a “United States real property holding corporation” within the meaning of Section 897(c)(2) of the Code.
Appears in 5 contracts
Samples: Merger Agreement, Merger Agreement (FOHG Holdings, LLC), Merger Agreement (Frederick's of Hollywood Group Inc /Ny/)
Tax Certification. Parent shall have received a certification from the Company in the form prescribed by Treasury regulations under Section 1445 of the Code to the effect that the Company is not (and was not at any time during the five-year period ending on the Closing Datedate) a “United States real property holding corporation” within the meaning of Section 897(c)(2) of the Code.
Appears in 2 contracts
Samples: Merger Agreement (Vectis Cp Holdings LLC), Merger Agreement (Insight Communications Co Inc)
Tax Certification. Parent Family LLC shall have received a certification from the Company in the form prescribed by Treasury regulations under Section 1445 of the Code to the effect that the Company is not (and was not at any time during the five-year period ending on the Closing Datedate of the Closing) a “United States real property holding corporation” within the meaning of Section 897(c)(2897 (c)(2) of the Code.
Appears in 2 contracts
Samples: Merger Agreement (Cablevision Systems Corp /Ny), Merger Agreement (Cablevision Systems Corp /Ny)
Tax Certification. Parent shall have received a certification from the Company in the form prescribed by Treasury regulations under Section 1445 of the Code to the effect that the Company is not (and was not at any time during the five-year period ending on the Closing Date) a “"United States real property holding corporation” " within the meaning of Section 897(c)(2) of the Code.
Appears in 2 contracts
Samples: Merger Agreement (Mod Pac Corp), Merger Agreement (Mod Pac Corp)
Tax Certification. Parent shall have received a certification from the Company in the form prescribed by Treasury regulations under Section 1445 of the Code to the effect that the Company is not (and was not at any time during the five-year period ending on the Closing Datedate) a “"United States real property holding corporation” " within the meaning of Section 897(c)(2) of the Code.
Appears in 1 contract
Tax Certification. Parent shall have received a certification from the Company in the form prescribed by Treasury regulations under Section 1445 of the Code to the effect that the Company is not (and was not at any time during the five-year Table of Contents period ending on the Closing Datedate) a “United States real property holding corporation” within the meaning of Section 897(c)(2) of the Code.
Appears in 1 contract
Samples: Merger Agreement (Critical Path Inc)
