United States Person. Seller is a “United States Person” within the meaning of Section 1445(f)(3) of the Internal Revenue Code of 1986, as amended, and shall execute and deliver an “Entity Transferor” certification at Closing.
United States Person. 58 VA...........................................................................58
United States Person. 45 Value ......................................................................................45
United States Person. Except as permitted by the Company, each Member represents and covenants that, for U.S. federal income tax purposes, it is and will at all times remain a “United States Person,” within the meaning of Code Section 7701, or is a disregarded entity the assets of which are treated as owned by a United States Person under Xxxxx. Reg. §§ 301.7701-1, 301.7701-2, and 301.7701-3.
United States Person. It is a United States person not subject to withholding under Section 1446 of the Code.
United States Person. The term ‘‘United States person’’ means—
(A) a United States citizen;
(B) a partnership, corporation, or other legal entity organized under the laws of the United States; and
(C) a partnership, corporation, or other legal entity that is organized under the laws of a foreign country and is controlled by en- tities described in subparagraph (B) or United States citizens, or both.
United States Person. Each Member covenants to the Company and each other Member that it (or, if it is an entity disregarded as separate from its owner for U.S. federal tax purposes, its owner for such purposes) will remain a “United States person” within the meaning of Section 7701(a)(30) of the Code and will not be subject to withholding under Section 1446 of the Code.
United States Person. Contributor is a “United States Person” within the meaning of Section 1445(f)(3) of the Code, as amended, and shall execute and deliver an “Entity Transferor” certification at Closing.
United States Person. (i) Any individual or business entity, regardless of location, that is a resident of the United States; (ii) any individual or business entity physically located within the United States; (iii) any business entity organized under the laws of the United States or of any state, territory, possession, or district thereof; and (iv) any business entity, wheresoever organized or doing business, which is owned or controlled by an individual or business entity specified in (i) or (iii) above.
United States Person. Each Seller is a United States person within the meaning of Section 7701(a)(30) of the Code.
