Common use of FIRPTA Certificate Clause in Contracts

FIRPTA Certificate. The Company shall have delivered to Parent a certificate, issued by the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying that the Company is not and has not been at any time during the five-year period ending on the Closing Date a United States real property holding corporation, as defined in Section 897(c)(2) of the Code.

FIRPTA Certificate. The At or prior to the Closing, the Company shall have deliver or cause to be delivered to the Parent (i) a certificate, issued by certificate of the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying that the Company is not not, and has not been at any time during the five-year period ending on the Closing Date been, a United States real property holding corporation, as defined within the meaning of Section 897 of the Code, during the applicable period specified in Section 897(c)(2897(c)(1)(a)(ii) of the CodeCode and (ii) a form of notice to the IRS prepared in accordance with the requirements of Treasury Regulation Section 1.897-2(h)(2).

FIRPTA Certificate. The Prior to the Closing, the Company shall have delivered deliver to Parent a certificate, issued by the Company pursuant to certificate in compliance with Treasury Regulations Section 1.1445-2(c) of the Treasury Regulations2(c)(3), certifying that the Company is Company’s U.S. subsidiaries are not and has not been at any time during the five-year period ending on the Closing Date a United States “U.S. real property holding corporation, ” (as defined in Section 897(c)(2) of the Code) during the applicable period specified in Section 897(c) of the Code (the “FIRPTA Certificate”).

FIRPTA Certificate. The Company shall have delivered to Parent a duly executed certificate, issued in form and substance as prescribed by the Company pursuant to Treasury regulations promulgated under Section 1.1445-2(c) 1445 of the Treasury RegulationsCode, certifying stating that the Company is not not, and has not been at any time been, during the five-year relevant period ending on specified in Section 897(c)(1)(A)(ii) of the Closing Date Code, a “United States real property holding corporation, as defined in ” within the meaning of Section 897(c)(2897(c) of the Code.

FIRPTA Certificate. The Immediately prior to the Closing, the Company shall have delivered deliver to Parent a certificate, issued certificate signed by an authorized officer of the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying effect that the Company is not not, and has not been at any time during the five-year period ending on five (5) years preceding the Closing Date Date, a United States real property holding corporationcompany, as defined in Section 897(c)(2) of the Code, conforming to the requirements of Treasury Regulations Section 1.1445-2(c)(3) and 1.897-2(h).

FIRPTA Certificate. The Company shall have delivered to Parent (i) a certificate, issued by properly executed certificate of the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying that the Company is not not, and has not been at any time during the five-year period ending on the Closing Date been, a United States real property holding corporation, as defined within the meaning of Section 897 of the Code, during the applicable period specified in Section 897(c)(2897(c)(1)(a)(ii) of the Code., which certificate complies with the requirements of Section 1445 of the Code and (ii) a form of notice to the IRS prepared in accordance with the requirements of Treasury Regulation Section 1.897-2(h)(2), each in substantially the form attached hereto as Exhibit A.

FIRPTA Certificate. The At or prior to the Closing, the Company shall have deliver or cause to be delivered to Parent (i) a certificate, issued by certificate of the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying that the Company is not not, and has not been at any time during the five-year period ending on the Closing Date been, a United States real property holding corporation, as defined within the meaning of Section 897 of the Code, during the applicable period specified in Section 897(c)(2897(c)(1)(a)(ii) of the CodeCode and (ii) a form of notice to the IRS prepared in accordance with the requirements of Treasury Regulation Section 1.897-2(h)(2).

FIRPTA Certificate. The Company shall have delivered to furnished Parent with a certificate, issued by the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying certificate stating that the Company is not and has not been at any time during the five-year period ending on the Closing Date a United States real property holding corporation, dated as defined in Section 897(c)(2) of the CodeClosing Date and in form and substance required under Treas. Reg. § 1.897-2(h).

FIRPTA Certificate. The Company shall have delivered to Parent a duly executed certificate, issued by the Company pursuant to Section 1.1445-2(c) dated as of the Closing Date, in form and substance as prescribed by Treasury Regulationsregulations promulgated under Section 1445 of the Code, certifying stating that the Company is not not, and has not been at any time been, during the five-year relevant period ending on specified in Section 897(c)(1)(A)(ii) of the Closing Date Code, a “United States real property holding corporation, as defined in ” within the meaning of Section 897(c)(2897(c) of the Code.

FIRPTA Certificate. The Company shall have delivered deliver to Parent, prior to the Closing, a statement in form and substance reasonably acceptable to Parent a certificate, issued by the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying that the Company is not and has not been at any no time during the five-year period ending on the Closing Date past five (5) years been a United States real property holding corporation, as defined in corporation within the meaning of Section 897(c)(2) of the Code.

FIRPTA Certificate. The At or prior to the Closing, the Company shall have delivered deliver to Parent a certificate, issued by the Company pursuant to certificate and IRS notice in form and substance required under Treasury Regulations Section 1.897-2(h) and 1.1445-2(c) of the Treasury Regulations, certifying stating that the Company is not and has not been at any time during the five-year relevant period ending on the Closing Date a “United States real property holding corporation, as defined in ” within the meaning of Section 897(c)(2) of the Code.

FIRPTA Certificate. The Company shall have delivered to Parent a certificate, issued by the Company pursuant to Section certificates prepared in accordance with Treasury regulations sections 1.1445-2(c) 2 and dated as of the Treasury Regulations, certifying that the Company is not and has not been at any time during the five-year period ending on the Closing Date certifying that it is not a “United States real property holding corporation, as defined in Real Property Holding Corporation” within the meaning of Section 897(c)(2) 897 of the Code.

FIRPTA Certificate. The Company shall have delivered to Parent a certificate, issued by the Company pursuant to Section 1.1445-2(c) duly executed certificate that complies with section 1445 of the Code and the Treasury Regulations, certifying Regulations promulgated thereunder and states that the Company is not and has not been at any time during the five-year period ending on the Closing Date a United States real property holding corporation, corporation (as defined in Section 897(c)(2) of the Code).

FIRPTA Certificate. The Company shall have delivered to provide Parent on the Closing Date with a certificate, issued by the Company pursuant to Section certificate in accordance with Treasury § 1.1445-2(c2(c)(3) of the Treasury Regulations, certifying that the Company is not and has not been at any time during the five-year period ending on the Closing Date a United States real property holding corporation, as defined in Section corporation within the meaning of Code § 897(c)(2) of the Code).

FIRPTA Certificate. The Company shall have delivered to Parent a certificate, issued by in form and substance reasonably satisfactory to Parent and meeting the Company pursuant to requirements of regulation Section 1.14451.897-2(c) of the Treasury Regulations2(h), certifying stating that the Company is not currently, and has not been at any time during the five-five year period ending on the Closing Date been, a "United States real property holding corporation, as defined in " within the meaning of Code Section 897(c)(2) of (the Code"FIRPTA Certificate").

FIRPTA Certificate. The Company shall have delivered to Parent a certificate, issued by as contemplated under and meeting the Company pursuant to requirements of Treasury Regulation Section 1.1445-2(c2(c)(3) of the Treasury Regulations, certifying that the Company is not and has not been at any time during the five-five (5) year period ending on the Closing Date a “United States real property holding corporation, ,” as defined in Section 897(c)(2) of the Code.

FIRPTA Certificate. The Company shall have delivered deliver to the Parent on the Closing Date, in a certificateform reasonably satisfactory to Parent, issued by the Company certification pursuant to Section 1.1445-2(c) the Treasury regulations under Sections 1445 and 897 of the Treasury Regulations, certifying Code to the effect that the Company is not and has not been at any time during the five-year period ending on the Closing Date a United States real property holding corporation, as defined in Section 897(c)(2) of the Codecompany.

FIRPTA Certificate. The Company shall have delivered to Parent a certificate, issued by the Company pursuant to Section 1.1445-2(c) of the Treasury Regulations, certifying that the Company is not and has not been at any time during the five-five (5) year period ending on the Closing Date a United States real property holding corporation, as defined in Section 897(c)(2) of the Code.