The Company shall deliver (i) to Buyer a certificate dated not more than twenty (20) days prior to the Closing Date that satisfies the requirements of Treasury Regulations Section 1.1445-2(c)(3) substantially in the form of Exhibit J, stating that an interest in the Company is not a U.S. real property interest as defined in Section 897 of the Code, and (ii) to the IRS the notification required under Treasury Regulation Section 1.897-2(h)(2) substantially in the form of Exhibit K .
firpta certificates