Extract to table

Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the Purchase Agreement

Section 1445 of the Internal Revenue Code of 1986, as amended (the "Code"), provides that a transferee of a "United States real property interest" (as defined in Section 897(c) of the Code) must withhold tax if the transferor is a "foreign person" (as defined in Section 7701 of the Code and the Treasury Regulations promulgated thereunder)

In the event of any such change in circumstances, Transferor shall deliver to Transferee a revised or updated certificate reflecting the then-current facts and circumstances, to the extent required by applicable law