The Contributor Not a Foreign Person. The Contributor is not a "foreign person" which would subject the Operating Partnership to the withholding tax provisions of Section 1445 of the Internal Revenue Code of 1986, as amended.
The Contributor Not a Foreign Person Sample Clauses
Related to The Contributor Not a Foreign Person
Not a Foreign Person Borrower is not a “foreign person” within the meaning of §1445(f)(3) of the Code.
Non-Foreign Person Seller is not a “foreign person” as defined in Section 1445 of the Internal Revenue Code, as amended (the “Code”).
Not Foreign Person Borrower is not a “foreign person” within the meaning of §1445(f)(3) of the Code.
Foreign Person Seller is not a “foreign person” as defined in Section 1445 of the Internal Revenue Code of 1986, as amended, and the Income Tax Regulations thereunder.
No Foreign Person Borrower is not a "foreign person" within the meaning of Section 1445(f)(3) of the Internal Revenue Code of 1986, as amended and the related Treasury Department regulations, including temporary regulations.
United States Person 58 VA...........................................................................58
Passive Foreign Investment Company The Company shall conduct its business, and shall cause its Subsidiaries to conduct their respective businesses, in such a manner as will ensure that the Company will not be deemed to constitute a passive foreign investment company within the meaning of Section 1297 of the Code.
Non-U.S. Person Any person other than a “United States person” within the meaning of Section 7701(a)(30) of the Code.
Investment Intent; Accredited Investor The Investor is purchasing the Note and the Warrant for its own account, for investment purposes, and not with a view towards distribution. The Investor is an “accredited investor” as such term is defined in Rule 501(a) of Regulation D of the 1933 Act. The Investor has, by reason of its business and financial experience, such knowledge, sophistication and experience in financial and business matters and in making investment decisions of this type that it is capable of (a) evaluating the merits and risks of an investment in the Note, the Warrant and the Investor Shares and making an informed investment decision, (b) protecting its own interests and (c) bearing the economic risk of such investment for an indefinite period of time.
Transfers to Non-QIB Institutional Accredited Investors The following provisions shall apply with respect to the registration of any proposed transfer of a Note to any Institutional Accredited Investor which is not a QIB (excluding Non-U.S. Persons):
