Real Property Holding Company. The Acquiror Company is not and has not been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code at any time during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 5 contracts
Samples: Share Exchange Agreement (Writers Group Film Corp), Share Exchange Agreement (Genesis Holdings, Inc.), Share Exchange Agreement (Parque La Quinta Estates)
Real Property Holding Company. The Acquiror Company is not and has not been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code at any time during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 2 contracts
Samples: Share Exchange Agreement (Skylab USA, Inc.), Share Exchange Agreement (Skylab USA, Inc.)
Real Property Holding Company. The Acquiror Company is not not, and has not been been, a "United States real property holding corporation corporation" within the meaning of Section 897(c)(2) of the Internal Revenue Code at any time of 1986, as amended (the "Code"), during the applicable period specified described in Section 897(c)(1)(A)(ii) of the Code.
Appears in 2 contracts
Samples: Preferred Stock Purchase Agreement (Amazon Com Inc), Stock Purchase Agreement (Amazon Com Inc)
Real Property Holding Company. The Acquiror Company is not and has not been a United States real property holding corporation within the meaning of Code Section 897(c)(2892(c)(2) of the Code at any time during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
Samples: Agreement and Plan of Merger
Real Property Holding Company. The Acquiror None of Company is not and its Subsidiaries has not been a United States real property holding corporation within the meaning of Code Section 897(c)(2) of the Code at any time during the applicable period specified in Code Section 897(c)(1)(A)(ii) of the Code).
Appears in 1 contract
Samples: Share Purchase Agreement (Miami Cruiseline Services Holdings I B V)
Real Property Holding Company. The Acquiror Company is and the Subsidiaries are not and has have not been a United States real property holding corporation within the meaning of companies (as defined in Section 897(c)(2) of the Code at any time Code) during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code.
Appears in 1 contract
