Real Property Holding Corporation. The Acquiror 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 12 contracts
Samples: Share Exchange Agreement (Bas Consulting Inc), Share Exchange Agreement (HPC Pos System, Corp.), Share Exchange Agreement (Laufer Bridge Enterprises, Inc.)
Real Property Holding Corporation. The Acquiror is not and No Acquired Entity is, or has not been been, a "United States real property holding corporation 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: Agreement and Plan of Merger and Reorganization (Microtune Inc), Agreement and Plan of Reorganization (Jda Software Group Inc)
Real Property Holding Corporation. The Acquiror is not and has not been a United States U.S. 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 (Sweets & Treats Inc.), Share Exchange Agreement (Sweets & Treats Inc.)
