FIRPTA Certificates definition

FIRPTA Certificates means the affidavit of each of the Contributors under Section 1445 of the Internal Revenue Code certifying that such Contributor is not a foreign corporation, foreign partnership, foreign trust, foreign estate or foreign person (as those terms are defined in the Internal Revenue Code and the Income Tax Regulations), in form and substance satisfactory to the Acquiror.

FIRPTA Certificates has the meaning set forth in Section 6.2(e).

FIRPTA Certificates has the meaning set forth in Section 2.04(a)(ii).

Examples of FIRPTA Certificates in a sentence

• Escrow Holder shall disburse to Buyer the Tenant Lease Assignment, the General Assignment, the FIRPTA Certificates, the Tenant Notification Letters, and change of address notices duly executed by Seller and any other documents (or copies thereof) deposited into Escrow by Seller pursuant hereto.

• Recitals Covered Cont ract Section 3.19 DOJ Section 5.06 Encumbrances Section 1.01 Excluded Assets Section 1.02 Excluded Liabilities Section 1.04 FIRPTA Certificates Section 2.02(b)(vii) GAAP Section 3.12 Governmental Requirements Section 3.07 HSR Act Section 3.07 Petitions ....................................................................................................................

• FIRPTA Certificates...............................................

• EXHIBIT N FIRPTA Certificates CERTIFICATION OF NON-FOREIGN STATUS ENTITY TRANSFEROR Section 1445 of the Internal Revenue Code provides that a transferee of a U.S. real property interest must withhold tax if the transferor is a foreign person.

• Section 10.2(g) of this Agreement sets forth a condition to Acquiror’s and the Tower Operator’s obligation to consummate the Initial Closing with respect to the provision of FIRPTA Certificates to Acquiror in connection with each Sale Site Subsidiary and provides certain withholding rights on a failure to provide such FIRPTA Certificates.

More Definitions of FIRPTA Certificates

FIRPTA Certificates has the meaning set forth in Section 3.02(a)(viii).

FIRPTA Certificates has the meaning set forth in Section 7.2(j).

FIRPTA Certificates means the FIRPTA Certificates executed by Seller, in substantially the form of Exhibit D hereto.

FIRPTA Certificates means the affidavit of Xxxxxxxx and PPL under Section 1445 of the Internal Revenue Code, as amended, certifying that neither Xxxxxxxx nor PPL is a foreign corporation, foreign partnership, foreign trust, foreign estate or foreign person (as those terms are defined in the Internal Revenue Code and regulations promulgated thereunder), in form and substance satisfactory to Brandywine OP.

FIRPTA Certificates means affidavits of Seller as required by Section 1445 of the Code in the forms attached hereto as Exhibit H.

FIRPTA Certificates means (i) a certificate, duly executed under penalties of perjury by an authorized officer of US Holdco and prepared in compliance with the requirements of U.S. Treasury Regulation Sections 1.897-2(g)(1)(ii), 1.897-2(h) and 1.1445-5(d)(2), to the effect that, at the time of the disposition of the shares of US Holdco by ITS Energy Services, the shares of US Holdco did not constitute a “U.S. real property interest” for purposes of Sections 897(c)(1)(A)(ii) and 1445 of the Code, as amended, and (ii) the related notice to the U.S. Internal Revenue Service (which notice shall be filed by US Holdco on or before the day of such disposition).

FIRPTA Certificates has the meaning set forth in Section 8.02(n).