Extract to table

All bracketed placeholders must be completed with the applicable transaction-specific information prior to execution

Capitalized terms used but not otherwise defined in this Certificate shall have the meanings ascribed to such terms in the Transaction Agreement

Each subsection must be completed with the applicable entity-specific information

Virgin Islands, as well as any interest, other than solely as a creditor, in any domestic corporation that is itself a United States real property holding corporation), additional analysis is required to determine whether the Company satisfies the asset-ratio test of Section 897(c)(2)

Except as expressly set forth in this Certificate, the Company makes no representation or warranty of any kind to the Acquiror with respect to the tax treatment of the Transactions, and nothing in this Certificate shall be deemed to expand or modify the representations, warranties, covenants, or obligations of the Company under the Transaction Agreement

Chief Executive Officer, Chief Financial Officer, President, General Counsel, or other duly authorized officer] Date: ________ INSTRUCTION: The date of execution should correspond to the closing date of the Transactions, or such other date as may be specified in the Transaction Agreement as the date on which this Certificate is required to be delivered