English to Polish Law/Patents Law (general) general

Post-closing of the Proposed Transaction and upon a disposition of the Target, the Client could be subject to the withholding taxes and filing requirements of FIRPTA if the Target is a USRPHC. We recommend further analysis to be completed to determine whether the Target is a USRPHC and obtaining a statement from the Target post-closing that it is not a USRPHC.
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Certain of the post-closing restructuring options being evaluated by the client could be impacted based on whether or not the Target is treated as a USRPHC, so further evaluation of this should be undertaken.
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If the US assets/subsidiaries are sold post-closing, the taxable gain from the sale could potentially be offset by NOLs due to the increased Section 382 limitation created by the NUBIG.