USRPHC. The Company has not been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 3 contracts
Samples: Merger Agreement (Unilens Vision Inc), Merger Agreement (Salix Pharmaceuticals LTD), Merger Agreement (Valeant Pharmaceuticals International, Inc.)
USRPHC. The Company is not now and has not never been a “United States real property holding corporation within the meaning of corporation” as defined in Section 897(c)(2) of the Code during and the applicable period specified in Section 897(c)(1)(A)(ii) of the CodeTreasury Regulations promulgated thereunder.
Appears in 2 contracts
Samples: Redemption Agreement (United Homes Group, Inc.), Redemption Agreement (Conversant Capital LLC)
USRPHC. The Company has not been a United States State real property holding corporation within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 2 contracts
Samples: Merger Agreement (Arthrocare Corp), Merger Agreement (Arthrocare Corp)
USRPHC. The Neither the Company nor the Company Subsidiary has not been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 2 contracts
Samples: Merger Agreement (Iparty Corp), Agreement and Plan of Merger (Microfluidics International Corp)
USRPHC. The Company has is not been a United States real property holding corporation within the meaning of Section Code §897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code).
Appears in 2 contracts
Samples: Stock Purchase Agreement (Remington Arms Co Inc/), Stock Purchase Agreement (Freedom Group, Inc.)
USRPHC. The Company has not been a “United States real property holding corporation corporation” within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
USRPHC. The Company has not never been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
Samples: Merger Agreement (Check Point Software Technologies LTD)
USRPHC. The Company has not never been a “United States real property holding corporation corporation” within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
Samples: Contribution Agreement (Cybin Inc.)
USRPHC. The Neither the Company nor any of its Subsidiaries has not been a “United States real property holding corporation corporation” within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
USRPHC. The Company has is not been a United States real property holding corporation within the meaning of Section Code section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.). (q)
Appears in 1 contract
USRPHC. The Company has not never been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
Samples: Merger Agreement (Check Point Software Technologies LTD)
USRPHC. The Company has is not been a United States real property holding corporation within the meaning of Section Code section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code).
Appears in 1 contract
USRPHC. The No Acquired Company has not been a “United States real property holding corporation corporation” within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
Samples: Share Purchase Agreement (Tessera Technologies Inc)
