Foreign Tax Matters. The Seller Interests have not and have never been United States real property interests as defined in Section 897(g) of the Code and the regulations thereunder.
Foreign Tax Matters. Company does not have a permanent establishment in any foreign country, as defined in any applicable Tax treaty or convention between the United States of America and such foreign country. Company has not participated in an international boycott as defined in Section 999 of the Code.
Foreign Tax Matters. Remainco shall, at its own expense, have exclusive responsibility and control of the Remainco Foreign Tax Matter and the New News Corporation Foreign Tax Matter. The Parties shall assist and cooperate with each other during the course of any such examination, audit or litigation. Remainco shall reimburse New News Corporation for all reasonable out-of-pocket costs and expenses incurred by the New News Corporation Group that directly relate to the Remainco Foreign Tax Matter and the New News Corporation Foreign Tax Matter within thirty (30) Business Days of receiving an invoice from New News Corporation therefor, including a calculation of the amount of costs or expenses that provides sufficient detail to permit Remainco to reasonably understand the calculations.
Foreign Tax Matters. The Company is not and has never been a United States real property holding corporation as defined in Section 897(c)(2) of the Code.
Foreign Tax Matters. Each Lender which is a foreign person (i.e., a Person other than a United States Person for United States Federal income tax purposes) hereby agrees that:
Foreign Tax Matters. Neither Target nor any Subsidiary organized outside of the United States is or has been classified as a passive foreign investment company, as defined in Section 1297 of the Code.
Foreign Tax Matters. 61 9.20 Responses to Requests..................................62
Foreign Tax Matters. Seller is not and has never been either (i) a United States real property holding corporation as defined in Section 897(c)(2) of the Code, or (ii) a foreign person as defined in Section 1445(f)(3) of the Code.
Foreign Tax Matters. The Company (i) has not been a shareholder of a “controlled foreign corporation” as defined in Section 957 of the Code (or any similar provision of applicable state, local or foreign law); (ii) has not been a shareholder of a “passive foreign investment company” within the meaning of Section 1297 of the Code; (iii) has not participated in or cooperated with, or agreed to participate in or cooperate with, an international boycott within the meaning of Section 999 of the Code and (iv) has not engaged in a trade or business, had a permanent establishment (within the meaning of an applicable Tax treaty), or otherwise become subject to Tax jurisdiction in a country other than the United States.
Foreign Tax Matters. Except as set forth on Schedule 3.6(k), the Company does not have a permanent establishment in any foreign country, as defined in any applicable Tax treaty or convention between the United States and such foreign country. Except as set forth on Schedule 3.6(k), none of the Subsidiaries is an entity that is disregarded for U.S. federal income tax purposes. The Company has not participated in an international boycott, as defined in Section 999 of the Code.
