Non-Foreign Status. Seller is not a “foreign person” as that term is defined in the Code and the regulations promulgated pursuant thereto.
Non-Foreign Status. Seller is not a “foreign person” as that term is used in Treasury Regulations Section 1.1445-2.
Non-Foreign Status. Contributor is not a foreign person for purposes of Section 1445(a) of the Code, and is, therefore, not subject to the provisions of the Code relating to the withholding of sales proceeds to foreign persons.
Non-Foreign Status. Seller is not a “foreign person” within the meaning of Section 1445 of the Code.
Non-Foreign Status. Seller is not a “foreign person” within the meaning of Paragraph 1445(f)(3) of the Internal Revenue Code of 1986, as amended.
Non-Foreign Status. The Contributor is not a foreign person, foreign corporation, foreign partnership, foreign trust or foreign estate (as defined in the Code), and is, therefore, not subject to the provisions of the Code relating to the withholding of sales proceeds to foreign persons.
Non-Foreign Status. Borrower is not a nonresident alien for purposes of U.S. income taxation and is not a foreign corporation, foreign partnership, foreign trust or foreign estate (as said terms are defined in the Code or regulations promulgated thereunder).
Non-Foreign Status. Each of Contributor and each Contributed Entity, or if any of the foregoing is an entity disregarded from its owner, the regarded owner of such entity, is a “United States person” (as defined in the Code).
Non-Foreign Status. The Company is a “United States person” (as defined in Section 7701(a)(30) of the Code).
Non-Foreign Status. Seller is not a "foreign person" as that term is defined in the Internal Revenue Code of 1986, as amended, and the regulations promulgated pursuant thereto, and Buyer has no obligation under the Internal Revenue Code Section 1445 to withhold and pay over to the Internal Revenue Service any part of the "amount realized" by Seller in the transaction contemplated hereby (as such term is defined in the regulations issued under Internal Revenue Code Section 1445).
