definiens: within the meaning ofTreasury Regulations Section 1.6011 - 4;(g ) Neither the Company nor any of its Subsidiaries has been a United States real property holding corporation within themeaning of Section 897 of the Code during the applicable period specified in Section 897(c)(1)(A)(ii ) of the Code;(h)(i ) Neither the Company nor any of its Subsidiaries is or has been a member of an affiliated group of corporationswithin the meaning of Section 1504 of the Code or any group that has filed a combined, consolidated or unitary Tax Return(other than the group of which the Company is or was the common parent ) ; and ( ii ) neither the Company nor any of itsSubsidiaries has any liability for the Taxes of any Person ( other than the Company or its Subsidiaries ) under TreasuryRegulations Section 1.1502 - 6 ( or any similar provision of state, local or foreign law ), as a transferee or successor, by contractor otherwise;(i ) There are no material Tax sharing agreements or similar arrangements, including Tax indemnity arrangements ( otherthan customary commercial or financial arrangements entered into in the ordinary course of business consistent with pastpractice ) with respect to or involving the Company or any of its Subsidiaries;(j ) means any Tax Return of, with respect to or that includes the Company or any of its Subsidiaries;(k ) means any tax or other like governmental assessment or charge of any kind whatsoever ( including : withholding required by applicable Tax law on amounts paid to or by any Person, together with any interest, penalty, additionto tax or additional amount with respect thereto, whether disputed or not;(l ) means any Governmental Authority responsible for the imposition of any Tax ; and(m ) means any report, return, document, declaration or other information required to be filed with orsupplied to a Taxing Authority, including information returns, any document with respect to or accompanying payments ofestimated Taxes, or with respect to or accompanying requests for the extension of time in which to file any such report, return, document, declaration or other information