Common use of Passive Foreign Investment Company Status Clause in Contracts

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 believes does not believe that it was not classified as a “passive foreign investment company within the meaning of section company” as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended (a “PFIC”)) for the taxable year ending December 31, for its prior taxable year2019, and the Company does not expect to be classified anticipate being treated as a PFIC for the taxable year of the Offering or in the foreseeable futureending December 31, 2020.

Passive Foreign Investment Company Status. The Company believes does not believe that it was not classified as a “passive foreign investment company within the meaning of section company” as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended (a “PFIC”), for its prior taxable year, and the Company does not expect to be classified anticipate being treated as a PFIC for the taxable year of the Offering or in the foreseeable futureending December 31, 2013.

Passive Foreign Investment Company Status. The Company believes that it was would not classified as have been a passive foreign investment company (“PFIC”) within the meaning of section Section 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, in the 2013 tax year had it been a “PFIC”), for separate taxable entity from the Parent and will not be a PFIC in its prior taxable initial year, and . The Company does not expect to be classified as become a PFIC for the year of the Offering or in the foreseeable future.

Passive Foreign Investment Company Status. The Company believes that does not believe it was not classified as is a passive foreign investment company (“PFIC”) within the meaning of section 1297 Section 1297(a) of the U.S. United States Internal Revenue Code of 1986, as amended (a “PFIC”), for its prior taxable yearamended, and does not expect intend to knowingly take any action that would or would be classified as likely to result in it becoming a PFIC for the year of the Offering or in the foreseeable futurePFIC.