U.S. Real Property Holding Corporation. The Company is not and has never been a United States real property holding corporation within the meaning of Section 897 of the Internal Revenue Code of 1986, as amended, and the Company shall so certify upon Purchaser’s request.
U.S. Real Property Holding Corporation. The Company is not and has never been a U.S. real property holding corporation within the meaning of [Section 897] of the
Real Property Holding Corporation. The Company is not and has 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.
U.S. Real Property Holding Corporation. Except as described in the Prospectus, the Company is not, nor has it ever been, a U.S. real property holding corporation within the meaning of Section 987 of the Code.
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