Common use of Passive Foreign Investment Company Status Clause in Contracts

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 current and anticipated value of its assets and the nature and composition of its income and assets, and subject Subject to the qualifications and assumptions set forth in the Registration Statement Statement, the Pricing Disclosure Package and the Prospectus, and based on the Company’s current projected income, assets and activities, the Company does not expect to that it will be classified as a “passive foreign investment company” within the meaning of Section company (a “PFIC”), as defined in section 1297 of the CodeInternal Revenue Code of 1986, as amended, for the taxable year ended June 30ending December 31, 2023; however authorities could take a contrary position2015.

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 Statement, the General Disclosure Package 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, 20232022; however authorities could take a contrary position.