U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not been a "United States real property holding corporation" as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and Section 1.897-2(b) of the Regulations thereunder.
Appears in 2 contracts
Samples: Convertible Debenture Purchase Agreement (Right Start Inc /Ca), Convertible Debenture Purchase Agreement (Right Start Inc /Ca)
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not been a "United States real property holding corporation" as defined in , within the meaning of Code Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and during the applicable period specified in Code Section 1.897-2(b) of the Regulations thereunder897(c)(1)(A)(ii).
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Cubist Pharmaceuticals Inc), Agreement and Plan of Merger and Reorganization (Cytyc Corp)
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not been a "“United States real property holding corporation" as defined in ” within the meaning of Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (during the "Code"applicable period specified in Section 897(c)(1)(A)(ii), and Section 1.897-2(b) of the Regulations thereunder.
Appears in 1 contract
Samples: Securities Purchase Agreement (Oncure Medical Corp)
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- not, and has not been in the period specified in Section 897(c)(1)(A)(ii) of the Code, a "“United States real property holding corporation" ” as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and Section 1.897-2(b) of the Regulations thereunder.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Castlight Health, Inc.)
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not never been a "United States real property holding corporation" as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and Section 1.897-2(b) of the Regulations thereunderpromulgated by the Internal Revenue Service, and the Company has filed with the Internal Revenue Service all statements, if any, wit its United States income tax returns which are required under Section 1.897(h) of such Regulations.
Appears in 1 contract
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not never been a "United States real property holding corporationReal Property Holding Corporation" as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and Section 1.897-2(b) of the Regulations thereunderpromulgated by the Internal Revenue Service.
Appears in 1 contract
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not never been a "United States real property holding corporation," as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and Section 1.897-2(b) of the Treasury Regulations thereunderand the Company has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of such Regulations.
Appears in 1 contract
U.S. Real Property Holding Corporation. The Company is not now and -------------------------------------- and has not never been a "United States real property holding corporation," as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and Section 1.897-2(b) of the Regulations thereunderpromulgated by the Internal Revenue Service, and the Company has filed with the Internal Revenue Service all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of such Regulations.
Appears in 1 contract
Samples: Preferred Stock Purchase Agreement (Mainspring Communications Inc)
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not been a "United States real property holding corporation" as defined during the applicable period provided in Section 897(c)(2897(c) of the U.S. Internal Revenue Code of 1986, as amended (the "“Code")”) a U.S. real property holding corporation within the meaning of Section 897 of the Code, and Section 1.897-2(b) of the Regulations thereunderCompany shall so certify upon the Representative’s request.
Appears in 1 contract
Samples: Underwriting Agreement (CardieX LTD)
U.S. Real Property Holding Corporation. The Company is not now -------------------------------------- and has not never been a "United States real property holding corporation," as defined in Section 897(c)(2) of the U.S. Internal Revenue Code of 1986, as amended (the "Code"), and Section 1.897-2(b) of the Regulations thereunderpromulgated by the U.S. Internal Revenue Service.
Appears in 1 contract
Samples: Preferred Stock Purchase Agreement (Unifi Communications Inc)
