Common use of Passive Foreign Investment Company Status Clause in Contracts

Passive Foreign Investment Company Status. The Corporation does not expect to be classified as a passive foreign investment company within the meaning of section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for its most recently completed taxable year, the year of the Offering or in the foreseeable future.

Passive Foreign Investment Company Status. The Corporation Company does not expect to be classified as a “passive foreign investment company company” for U.S. federal income tax purposes within the meaning of section Section 1297 of the U.S. United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its most recently completed 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 year meaning of Section 957 of the Offering or Code and does not expect to become a controlled foreign corporation in the foreseeable future.

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