Real Estate Holding Company. To facilitate the overall development of the Project, the Developer may, at or prior to the Project Commencement Closing, assign its rights and obligations under the Purchase Agreement to an entity to be formed by the Developer (the “Holding Company”) as set forth in the Purchase Agreement. In the event the Holding Company is formed, the Holding Company will take title to the Property subject to this Agreement and the terms, conditions, covenants and obligations set forth herein.
Real Estate Holding Company. UAB has not been a United States real property holding corporation within the meaning of the Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Real Estate Holding Company. Tri-Valley has not been a United States real property holding corporation within the meaning of the Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Real Estate Holding Company. Presidio has not been a United States real property holding corporation within the meaning of the Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Real Estate Holding Company. Neither Focus nor any of its Subsidiaries has been a United States real property holding corporation within the meaning of the Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Real Estate Holding Company. NuTool is not nor has been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code and neither ASM nor Acquisition are required to withhold any taxes by virtue of the Merger by reason of Section 1445 of the Code.
Real Estate Holding Company. To facilitate the overall development of the Project, the Developer may, assign its rights and obligations under one or more of the Ground Lease Agreements to one or more entities to be formed by the Developer (the “Holding Company or Holding Companies” as the case may be) as further set forth in the Ground Lease Agreements.
Real Estate Holding Company. Neither GPP nor an Affiliate has been a United States real property holding corporation with the meaning of Section 897(c)(2) of the Code.
Real Estate Holding Company. Neither the Company nor any of its Subsidiaries has been a United States real property holding corporation within the meaning of the Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Real Estate Holding Company. The Company is not as of the date --------------------------- hereof, has not been at any time during the preceding year, and does not anticipate becoming in the future, a "United States real property holding corporation" within the meaning of Section 897(c)(2) of the Internal Revenue Code of 1986, as amended, and the Treasury regulations promulgated thereunder.
