Section 897 Sample Clauses

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Section 897. Neither the Company nor any Subsidiary: (i) is or has ever been a United States real property holding corporation within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code; or (ii) has made the election provided under section 897(i) of the Code.
Section 897. The Company: (i) is not and has never been a “United States real property holding corporation” within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code; and (ii) has not made the election provided under section 897(i) of the Code.
Section 897. No Acquired Entity is or has been a “United States real property holding corporation” within the meaning of Section 897 or Section 1445 of the Code, and each Acquired Entity has filed with the Internal Revenue Service all statements, if any, which are required under United States Treasury Regulations Section 1.897-2(h)(2).
Section 897. None of the Acquired Companies is, or has been, a “United States real property holding corporation” within the meaning of Section 897 or Section 1445 of the Code during the applicable period specified in Section 897(c)(1)(A) of the Code, and each of the Acquired Companies has filed with the Internal Revenue Service all statements, if any, which are required under Treasury Regulation Section 1.897-2(h).
Section 897. The Company is not and has never been a “United States real property holding corporation” within the meaning of Section 897 of the Code, and the Company has filed with the IRS all statements, if any, which are required under Section 1.897-2(h) of the Treasury Regulations.
Section 897. No member of Parent Group: (i) is or has ever been a “United States real property holding corporation” within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code; or (ii) has made the election provided under section 897(i) of the Code.
Section 897. No Company has been a “United States real property holding corporation” within the meaning of Section 897 of the Code within the period described in Section 897(c)( 1 )(A)(ii).
Section 897. Parent: (i) is not and has never been a "United States real property holding corporation" within the meaning of Section 897(c)(2) of the Code during the applicable period specified in Section 897(c)(1)(A)(ii) of the Code; and (ii) has not made the election provided under section 897(i) of the Code.