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.
Appears in 6 contracts
Samples: Agreement and Plan of Merger (Roku, Inc), Agreement and Plan of Reorganization (FireEye, Inc.), Agreement and Plan of Merger (FireEye, Inc.)