United States real property interest definition

United States real property interest means any direct or indirect interest in United States real property as defined in Section 897(c) of the Code and the Regulations promulgated thereunder.
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United States real property interest generally means an ownership interest in real property located in the United States or the Virgin Islands and any equity interest in certain domestic corporations or partnerships that hold real property interests, but would not include a mortgage loan unless it provided for contingent interest payments based upon the income from or value of the real property securing such loan.
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United States real property interest has the meaning provided to such term for purposes of Sections 897 and 1445 of the Code and the Treasury Regulations thereunder.
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Examples of United States real property interest in a sentence

  • In addition, upon a written request by an Investor, the Company shall provide such Investor with a written statement informing such Investor whether such Investor’s interest in the Company constitutes a United States real property interest.

  • Our stock will not constitute a United States real property interest if we are a domestically-controlled REIT.

  • Within a reasonable period following (and in any event within 20 days after receipt of) written request by an Investor, the Company shall provide such Investor with a written statement informing such Investor whether such Investor’s interest in the Company constitutes a United States real property interest.


More Definitions of United States real property interest

United States real property interest. (as defined in Section 897(c)(1) of the Code and the regulations promulgated thereunder), together with a notice to the IRS (which shall be filed by Buyer with the IRS following the Closing) in accordance with the provisions of Treasury Regulation Section 1.897-2(h)(2). 8.6.
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United States real property interest as defined in Section 897 of the Code and the Treasury Regulations issued thereunder (a “USRPI”), or (B) a Purchased Entity that is a domestic corporation for U.S. federal income tax purposes, a duly executed certificate, dated as of the Closing Date, in compliance with Treas. Reg. §1.1445-2(b)(2), stating that such Seller is not a “foreign person” as defined in Section 1445 of the Code; and (ii) in the case of each Seller transferring assets that do not constitute a USRPI, a statement certifying that none of the assets transferred by such Seller include a USRPI; 16 (j) copies of UCC-3 termination or partial release statements, releases and/or such other documentation reasonably requested by Buyer, in each case, in form and substance reasonably satisfactory to Buyer, evidencing the release of (a) Liens on the Purchased Assets and the Interests arising pursuant to the Huron Credit Agreement and (b) the Liens described on Section 3.2(j) of the Sellers Disclosure Schedule; (k) the certificate required by Section 11.1(d); and (l) such other documents and instruments as may be reasonably necessary to consummate the transactions contemplated by this Agreement. Section 3.3
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United States real property interest as defined in Section 897 of the Code; (e) no Liens (other than Permitted Liens) for material Taxes have been filed and no material claims for Taxes have been asserted in writing with respect to the Business, the Acquired Assets or the Assumed Liabilities; (f) Parent and Seller and any affiliated group, within the meaning of Section 1504 of the Code, of which Parent or Seller is or has been a member, (i) has filed or caused to be filed in a timely manner (within any applicable extension periods) all material Tax returns, reports and forms required to be filed by the Code or by applicable state, local or foreign Tax laws and (ii) all Taxes due on such returns, reports and forms have been timely paid in full or will be timely paid in full by the due date thereof; (g) none of Parent or Seller has been a member of an affiliated group, within the meaning of Section 1504 of the Code, filing a consolidated Federal income tax return (other than a group the common parent of which was Parent); and (h) none of Parent or Seller has any liability for the Taxes of any Person (other than any of Parent or Seller) under Regulation Section 1.1502-6 (or any similar provision of state, local, or foreign law) or pursuant to any tax allocation or sharing agreement.
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United States real property interest generally means an ownership interest in real property located in the United States or the U.S. Virgin Islands, an ownership interest in certain partnerships that hold
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Related to United States real property interest

  • Real Property Interests means all interests in Owned Real Property and Leased Real Property, including fee estates, leaseholds and subleaseholds, purchase options, easements, licenses, rights to access, and rights of way, and all buildings and other improvements thereon and appurtenant thereto, owned or held by Sellers that are used in the business or operations of the Stations, together with any additions, substitutions and replacements thereof and thereto between the date of this Agreement and the Closing Date, but excluding the Excluded Real Property Interests.

  • 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.

  • Real Property means, collectively, all right, title and interest (including any leasehold, mineral or other estate) in and to any and all parcels of or interests in real property owned or leased by any Person, whether by lease, license or other means, together with, in each case, all easements, hereditaments and appurtenances relating thereto, all improvements and appurtenant fixtures and equipment, all general intangibles and contract rights and other property and rights incidental to the ownership, lease or operation thereof.

  • Owned Real Property has the meaning set forth in Section 4.10(a).

  • Rental Property means a hotel room, vacation home, or other rental property You booked for Your stay during Your Trip.

  • District Property means all property owned by the District including, but not limited to, the Amenity Center, common areas, parking lots and ponds.

  • Eligible Real Property means, at any time of determination, Real Property owned by Borrower which Lender, in its sole discretion, deems to be eligible for borrowing purposes.

  • Leased Real Property has the meaning set forth in Section 3.18(b).

  • Real Estate Assets means any investment by the Company or the Operating Partnership in unimproved and improved Real Property (including fee or leasehold interests, options and leases), directly, through one or more subsidiaries or through a Joint Venture.

  • Excluded Real Property (a) any Real Property that is subject to a Lien expressly permitted by Section 7.3(j) (solely to the extent that the Indebtedness secured by such Lien would prohibit a Lien on such Real Property to secure the Obligations) or Section 7.3(g) (solely to the extent securing Indebtedness under Sections 7.2(c) or 7.2(t)), (b) any Real Property with respect to which, in the reasonable judgment of the Borrower and the Administrative Agent, the cost of providing a mortgage on such Real Property in favor of the Secured Parties under the Security Documents shall be excessive in view of the benefits to be obtained by the Lenders therefrom and (c) any Real Property to the extent providing a mortgage on such Real Property would (i) result in material adverse tax consequences to Holdings or the Borrower or any of its Restricted Subsidiaries as reasonably determined by the Borrower (provided, that any such designation of Real Property as Excluded Real Property shall be subject to the prior written consent of the Administrative Agent (such consent not to be unreasonably withheld or delayed)), (ii) violate any applicable Requirement of Law, (iii) be prohibited by any applicable Contractual Obligations (other than customary non-assignment provisions which are ineffective under the Uniform Commercial Code) to the extent such prohibition was not created in contemplation of a mortgage on such Real Property or (iv) give any other party (other than a Loan Party or a wholly-owned Subsidiary) to any contract, agreement, instrument or indenture governing such Real Property the right to terminate its obligations thereunder (other than customary non-assignment provisions which are ineffective under the Uniform Commercial Code or other applicable law) to the extent such right was not created in contemplation of a mortgage on such Real Property; provided that the Borrower may designate in a written notice to the Administrative Agent any Real Property not to constitute “Excluded Real Property”, whereupon the Borrower shall be obligated to comply with the applicable requirements of Section 6.8 as if it were newly acquired.

  • United States Tax Person A citizen or resident of the United States, a corporation, partnership or other entity created or organized in, or under the laws of, the United States, any State thereof or the District of Columbia, an estate whose income from sources without the United States is includible in gross income for United States federal income tax purposes regardless of its source or a trust if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more United States Tax Persons have the authority to control all substantial decisions of the trust, all within the meaning of Section 7701(a)(30) of the Code (or, to the extent provided in the applicable Treasury Regulations, certain trusts in existence on August 20, 1996 that have elected to be treated as United States Tax Persons).

  • Real means, in the context of offset projects, that GHG reductions or GHG enhancements result from a demonstrable action or set of actions, and are quantified using appropriate, accurate, and conservative methodologies that account for all GHG emissions sources, GHG sinks, and GHG reservoirs within the offset project boundary and account for uncertainty and the potential for activity- shifting leakage and market-shifting leakage.

  • Parcel means an identifiable unit of land that is treated as separate for valuation or zoning purposes.