United States Real Property Holding Corporation definition

United States Real Property Holding Corporation within the meaning of Section 897(c)(2) of the Code.
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United States Real Property Holding Corporation shall have the meaning set forth in Section 3.9(h).
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United States Real Property Holding Corporation dated not more than thirty (30) days prior to the Closing Date, as described in Treasury Regulations Sections 1.897-2(h) and 1.1445-2(c)(3), and (ii) proof of delivery to the IRS of the required notice, as described in Treasury Regulations 1.897-2(h)(2).
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Examples of United States Real Property Holding Corporation in a sentence

  • The Company is not now and has never been a "United States Real Property Holding Corporation" as defined in Section 897(c)(2) of the Code and Section 1.897-2(b) of the Regulations promulgated by the Internal Revenue Service.

  • Finally, dividends paid by a United States Real Property Holding Corporation are not considered to be income from the exploitation of real property: such payments would fall under Article 10 (Dividends) or 13 (Capital Gains).

  • Finally, dividends paid by a United States Real Property Holding Corporation are not considered to be income from the exploitation of real property: such payments would fall under Article 10 (Dividends) or 13(Gains).

  • Finally, distributions from a United States Real Property Holding Corporation are not considered to be income from the exploitation of real property; such payments would fall under Article 10 or 13.Paragraph 4This paragraph specifies that the basic rule of paragraph 1 (as elaborated in paragraph 3) applies to income from real property of an enterprise.

  • Neither the Company nor any Subsidiary is now nor has ever been a "United States Real Property Holding Corporation" as defined in Section 897(c)(2) of the Code and Section 1.897-2(b) of the Regulations promulgated by the Internal Revenue Service.

  • Any notice conforming with or under Treasury Regulation Section 1.897-2(h) need address the status of the Company as a United States Real Property Holding Corporation and the status of the Company Shares as a United States Real Property Interest only from a date that is no earlier than the day that is thirty days prior to the Effective Time.

  • The Company is not and has not ever been a "United States Real Property Holding Corporation" (a "USRPHC") as that term is defined in section 897(c)(2) of the Code and the Treasury Regulations thereunder (the "Treasury Regulations").

  • Upon request by Parent after the Effective Time, the Company shall use its best efforts to deliver to the Internal Revenue Service a notice that it is not a "United States Real Property Holding Corporation" as defined in and in accordance with the requirements of Treasury Regulation Section 1.897-2(h)(2).

  • The Company is not a United States Real Property Holding Corporation within the meaning of Section 897 (c)(2) of the Code.

  • The Company is not, and during the five-year period ending on the Closing Date has not been, a "United States Real Property Holding Corporation," as such term is defined in Section 897(c) of the Code or the Treasury Regulations promulgated thereunder.


More Definitions of United States Real Property Holding Corporation

United States Real Property Holding Corporation within the meaning of Section 897(c) of the Code. (p) Each of the Real Estate Sellers and the GH Company is currently taxed as a “disregarded entity” for U.S. federal income Tax purposes pursuant to Treasury Regulation Section 301.7701-3(b)(1)(ii) and no election has been made (or is pending) to change such treatment. (q) RW Company and RW Seller are each currently taxed as a “C corporation” for U.S. federal income Tax purposes pursuant to Treasury Regulation Section 301.7701-2(b) and no election has been made (or is pending) to change such treatment.
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United States Real Property Holding Corporation has the meaning set forth in Section 4.8(f).
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Related to United States Real Property Holding Corporation

  • Public utility holding company means: (1) any company that,

  • Qualified United States financial institution means an institution that:

  • Mutual housing corporation means a corporation not-for-profit,

  • Foreign Holding Company means any Domestic Subsidiary substantially all of the assets of which consist of Equity Interests and/or Indebtedness of one or more Foreign Subsidiaries or other Foreign Holding Companies.

  • Qualified CFC Holding Company means a Wholly Owned Subsidiary of the Issuer that is a limited liability company, the primary asset of which consists of Equity Interests in either (i) a Foreign Subsidiary or (ii) a limited liability company the primary asset of which consists of Equity Interests in a Foreign Subsidiary.

  • Foreign nonprofit corporation means an entity:

  • CFC Holding Company means a Subsidiary, substantially all of the assets of which consist of Equity Interests or Indebtedness of (a) one or more CFCs or (b) one or more CFC Holding Companies.

  • United States Citizen shall have the meaning set forth in Section 3.02.

  • Foreign Subsidiary Holding Company means any Subsidiary the primary assets of which consist of Capital Stock in (i) one or more Foreign Subsidiaries or (ii) one or more Foreign Subsidiary Holding Companies.

  • Community basin means an infiltration system, sand filter designed to infiltrate, standard constructed wetland, or wet pond, established in accordance with N.J.A.C. 7:8-4.2(c)14, that is designed and constructed in accordance with the New Jersey Stormwater Best Management Practices Manual, or an alternate design, approved in accordance with N.J.A.C. 7:8-5.2(g), for an infiltration system, sand filter designed to infiltrate, standard constructed wetland, or wet pond and that complies with the requirements of this chapter.

  • Residential real property means real property improved by a one to four family dwelling used or occupied, or intended to be used or occupied, wholly or partly, as the home or residence of one or more persons, but shall not refer to (a) unimproved real property upon which such dwellings are to be constructed or (b) condominium units or cooperative apartments or (c) property on a homeowners’ association that is not owned in fee simple by the seller.

  • Mutual holding company means that term as defined in section 10(o) of the home owners' loan act, chapter 64, titles III and IX of Public Law 101-73, 12 U.S.C. 1467a, and OTS regulations governing mutual holding companies.

  • Bank Holding Company Act means the Bank Holding Company Act of 1956, as amended.

  • Domestic Corporation means an entity that is treated as a corporation for United States federal income tax purposes and is a U.S. Tax Person.

  • financial holding company means a financial holding company as defined in point (20) of Article 4(1) of Regulation (EU) No 575/2013;

  • General Motors Financial Company, Inc. means General Motors Financial Company, Inc. (f/k/a AmeriCredit Corp.).

  • Urban transit hub means an urban transit hub, as defined in

  • Residential district means an area of a municipality where 75% or more of the area is zoned for residential housing.

  • mixed financial holding company means a mixed financial holding company as defined in point (21) of Article 4(1) of Regulation (EU) No 575/2013;

  • Community air carrier means an air carrier with a valid operating licence granted by a Member State in accordance with Council Regulation (EEC) No 2407/92 of 23 July 1992 of licensing of air carriers(7) ;

  • Domestic Foreign Holding Company means any Domestic Subsidiary that is a disregarded entity for U.S. federal income tax purposes with no material assets other than Equity Interests and/or Indebtedness of one or more Foreign Subsidiaries and other assets incidental thereto.

  • School District/Public Entity means the School District/Public Entity that executes the contract.

  • Subchapter S Corporation (as defined in the Internal Revenue Code of 1986, as amended), Borrower may pay cash dividends on its stock to its shareholders from time to time in amounts necessary to enable the shareholders to pay income taxes and make estimated income tax payments to satisfy their liabilities under federal and state law which arise solely from their status as Shareholders of a Subchapter S Corporation because of their ownership of shares of stock of Borrower, or (d) purchase or retire any of Borrower's outstanding shares or alter or amend Borrower's capital structure.

  • Residential real estate means any real property located in this state, upon which is constructed or intended to be constructed a dwelling;

  • Bank Holding Company means a company registered as such with the Federal Reserve pursuant to 12 U.S.C. §1842 and the regulations of the Federal Reserve promulgated thereunder.

  • Trinity House means the Corporation of Trinity House of Deptford Strond;