Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Closing shall not be, a “United States real property holding corporation,” as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “United States real property holding corporation,” and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 4 contracts
Samples: Convertible Preferred Stock Purchase Agreement (Collegium Pharmaceutical, Inc), Convertible Preferred Stock Purchase Agreement (Collegium Pharmaceutical Inc), Registration Rights Agreement (Seachange International Inc)
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Closing shall not be, a “United States real property holding corporation,” as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “United States real property holding corporation,” and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 3 contracts
Samples: Common Stock Purchase Agreement (Dynamic Leisure Corp), Common Stock Purchase Agreement (Dynamic Leisure Corp), Common Stock Purchase Agreement (Dynamic Leisure Corp)
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Initial Tranche 1 Closing shall not be, a “United States real property holding corporation,” as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “United States real property holding corporation,” and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 2 contracts
Samples: Convertible Preferred Stock Purchase Agreement (Collegium Pharmaceutical Inc), Convertible Preferred Stock Purchase Agreement (Collegium Pharmaceutical, Inc)
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Closing Date shall not be, a “United States real property holding corporation,” as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-1.897 2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “United States real property holding corporation,” and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-1.897 2(h) of the Treasury Regulations. The shares of the Company do not derive their value principally from real property, and the property of the Company does not and will not consist principally of real property.
Appears in 2 contracts
Samples: Stock and Warrant (Neurologix Inc/De), Stock and Warrant (Neurologix Inc/De)
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Closing this Agreement shall not be, a “United States real property holding corporation,” as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “United States real property holding corporation,” and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 2 contracts
Samples: Stock Purchase Agreement (Coley Pharmaceutical Group, Inc.), Stock Purchase Agreement (Coley Pharmaceutical Group, Inc.)
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Closing shall not be, a “United States real property holding corporation,” as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “United States real property holding corporation,” and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 1 contract
Samples: Convertible Preferred Stock Purchase Agreement (Collegium Pharmaceutical, Inc)
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Closing shall not be, a “"United States real property holding corporation,” " as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “"Code”"), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “"United States real property holding corporation,” " and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 1 contract
Samples: Voxware Inc
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Initial Closing shall not be, a “"United States real property holding corporation,” " as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “"United States real property holding corporation,” " and the Company has filed with the IRS all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 1 contract
Samples: Convertible Preferred Stock Purchase Agreement (Fastnet Corp)
Real Property Holding Corporation. Since its date of incorporation, the Company has not been, and as of the date of the Closing shall not be, a “United States real property holding corporation,” as defined in Section 897(c)(2) of the Internal Revenue Code of 1986 (the “Code”), and in Section 1.897-2(b) of the Treasury Regulations issued thereunder. The Company has no current plans or intentions which would cause the Company to become a “United States real property holding corporation,” and the Company has filed with the IRS Internal Revenue Service all statements, if any, with its United States income tax returns which are required under Section 1.897-2(h) of the Treasury Regulations.
Appears in 1 contract
