Passive Foreign Investment Company Status. Based on the Company’s current estimates of its gross income and the value of its gross assets (including goodwill) and the manner in which the Company conducts its business, the Company was not a Passive Foreign Investment Company within the meaning of Section 1297 of the Code (a “PFIC”) for the taxable year ended December 31, 2021 and does not expect that it will become a PFIC for the taxable year ending December 31, 2022.
Passive Foreign Investment Company Status. The Company believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, believes that it will not be a PFIC for its current taxable year and, based on the Company’s current operations and future projections, does not expect to be classified as a PFIC for any subsequent taxable year.
Passive Foreign Investment Company Status. The Company believes that it was not classified as a passive foreign investment company within the meaning of section 1297 of the U.S. Internal Revenue Code of 1986, as amended (a “PFIC”), for its prior taxable year, and does not expect to be classified as a PFIC for the year of the Offering or in the foreseeable future.
Passive Foreign Investment Company Status. The Company was not, for the taxable year ended December 31, 2009, and, after giving effect to the offering and sale of the Offered Shares and the application of the proceeds thereof as described in the Registration Statement, the Pricing Disclosure Package and the Prospectus, does not expect to become in the future, a “passive foreign investment company” as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder.
Passive Foreign Investment Company Status. Based on the current and anticipated value of its assets and the nature and composition of its income and assets, and subject to the qualifications set forth in the Registration Statement and the Prospectus, the Company does not expect to be a “passive foreign investment company” within the meaning of Section 1297 of the Code, for the taxable year ended June 30, 2023; however authorities could take a contrary position.
Passive Foreign Investment Company Status. Based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a “passive foreign investment company” as such term is defined in the Code for its current taxable year or for any subsequent taxable year.
Passive Foreign Investment Company Status. The Company does not expect to be a “passive foreign investment company” for U.S. federal income tax purposes within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending July 31, 2020 or for any foreseeable subsequent taxable year. The Company is not currently a “controlled foreign corporation” for U.S. federal income tax purposes within the meaning of Section 957 of the Code and does not expect to become a controlled foreign corporation in the foreseeable future.
Passive Foreign Investment Company Status. Based on certain estimates of its gross income and gross assets, the latter determined by reference to the expected market value of the Company’s shares when issued and assuming that the Company is entitled to value its intangible assets with reference to the market value of its shares, the Company’s intended use of the proceeds of this offering, and the nature of the Company’s business, the Company does not expect that it will become a Passive Foreign Investment Company within the meaning of Section 1297 of the Code.
Passive Foreign Investment Company Status. Based on the Company's gross income and gross assets and the nature of the Company's business, the Company does not believe it was a Passive Foreign Investment Company within the meaning of Section 1297 of the Code for the taxable year ended June 30, 2023. (ggg) Additional representations related to Canadian legal matters.
Passive Foreign Investment Company Status. Based on the Company’s current and projected income, assets and activities, the Company does not expect to be a passive foreign investment company within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”) for U.S. federal income tax purposes for its current taxable year or in the foreseeable future. If an investor provides reasonable notice to the Company that it has determined to make a “Qualified Electing Fund” election pursuant to Section 1295 of the Code, the Company shall promptly, and in any event no later than the date that is 75 days after the end of the taxable year of the Company, provide annual financial information to such investor in the “PFIC Annual Information Statement” (within the meaning of Treasury Regulations section 1.1295-1(g)) and shall provide the investor with access to such other Company information as may be reasonably required for purposes of filing United States federal income tax returns in connection with such Qualified Electing Fund election.”
