Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company does not expect to be a passive foreign investment company (as defined in Section 1297 of the Code) for its current taxable year or in the foreseeable future.

Appears in 15 contracts

Samples: Underwriting Agreement (Globavend Holdings LTD), Underwriting Agreement (Delixy Holdings LTD), Underwriting Agreement (SAG Holdings LTD)

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Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does not expect to be believe that it is a passive foreign investment company (company, as defined in Section section 1297 of the Code) for its current taxable year or in the foreseeable future.

Appears in 8 contracts

Samples: Cambium Networks Corp, Cambium Networks Corp, Underwriting Agreement (New Business Netherlands N.V.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does not expect to be believe that it is a passive foreign investment company (a “PFIC”), as defined in Section section 1297 of the Code) for its current taxable year or in the foreseeable futureInternal Revenue Code of 1986, as amended.

Appears in 6 contracts

Samples: Underwriting Agreement (Axalta Coating Systems Ltd.), Underwriting Agreement (Axalta Coating Systems Ltd.), Underwriting Agreement (Axalta Coating Systems Ltd.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package Packages and the Final Prospectus, the Company believes that it was not a passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended, for its most recently completed taxable year and it does not expect to be a passive foreign investment company (as defined in Section 1297 of the Code) PFIC for its current taxable year or in the foreseeable futureyear.

Appears in 4 contracts

Samples: Underwriting Agreement (MeiraGTx Holdings PLC), Underwriting Agreement (MeiraGTx Holdings PLC), Underwriting Agreement (MeiraGTx Holdings PLC)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions limitations and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package and the Final Prospectus, the Company does not expect to be treated as a passive foreign investment company (as defined in “PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code) ”), for its current taxable year or in the foreseeable futurefor future taxable years.

Appears in 4 contracts

Samples: Underwriting Agreement (Venator Materials PLC), Underwriting Agreement (Venator Materials PLC), Underwriting Agreement (Venator Materials PLC)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does not expect to be believe it was classified as a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current the Company’s taxable year or in the foreseeable futureended March 31, 2018.

Appears in 3 contracts

Samples: Sales Agreement (Axovant Gene Therapies Ltd.), Sales Agreement (Axovant Gene Therapies Ltd.), Sales Agreement (Axovant Sciences Ltd.)

Passive Foreign Investment Company. Subject to the limitations, qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company does not presently expect to be a passive foreign investment company (company” as defined in Section 1297 of the Code) Code for its the current taxable year or in the foreseeable future.

Appears in 2 contracts

Samples: Underwriting Agreement (Viking Holdings LTD), Underwriting Agreement (Viking Holdings LTD)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (a “PFIC”), as defined in Section section 1297 of the Code) for its current taxable Internal Revenue Code of 1986, as amended, in any tax year ended on or in the foreseeable futurebefore December 31, 2017.

Appears in 2 contracts

Samples: Letter Agreement (Cision Ltd.), Letter Agreement (Cision Ltd.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does not expect to be a passive foreign investment company (a “PFIC”), as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended for its current 2017 taxable year or in the foreseeable futureyear.

Appears in 2 contracts

Samples: Underwriting Agreement (InflaRx N.V.), Underwriting Agreement (Fireman B.V.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions qualifications and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company does not expect to be a passive foreign investment company company” (“PFIC”) as defined in Section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureyear.

Appears in 2 contracts

Samples: Kingsoft Cloud Holdings LTD, Kingsoft Cloud Holdings LTD

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company believes that it was not a passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the Internal Revenue Code of 1986, as amended, for its most recently completed taxable year and it does not expect to be a passive foreign investment company (as defined in Section 1297 of the Code) PFIC for its current taxable year or in the foreseeable futureyear.

Appears in 2 contracts

Samples: Sales Agreement (MeiraGTx Holdings PLC), Sales Agreement (MeiraGTx Holdings PLC)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2015.

Appears in 2 contracts

Samples: Underwriting Agreement (Ascendis Pharma a/S), Deposit Agreement (Ascendis Pharma a/S)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (a “PFIC”), as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its most recent taxable year, and the Company does not expect to become a PFIC in the current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Letter Agreement (Canuelas Mill S.A.C.I.F.I.A.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Time of Sale Prospectus and the Final Prospectus, the Company does not expect to be believe it was classified as a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current the Company’s taxable year or in the foreseeable futureended March 31, 2019.

Appears in 1 contract

Samples: Underwriting Agreement (Axovant Gene Therapies Ltd.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth other than as disclosed in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company should not be characterized as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the Code for the current taxable year and the Company does not expect to be a passive foreign investment company (as defined in Section 1297 of the Code) PFIC for its current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Underwriting Agreement (Fidelis Insurance Holdings LTD)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Time of Sale Prospectus and the Final Prospectus, the Company does not expect to be believe it was classified as a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current the Company’s taxable year or in the foreseeable futureended March 31, 2018.

Appears in 1 contract

Samples: Underwriting Agreement (Axovant Sciences Ltd.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions expectations and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company does not expect to be a passive foreign investment company (company” as defined in Section 1297 of the Code) Code for its the current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Enlight Renewable Energy Ltd.

Passive Foreign Investment Company. Subject Except as disclosed in the Registration Statement and the Prospectus and subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does believes that it was not expect to be a passive foreign investment company company” (“PFIC”) as defined in Section 1297 of the Code) Code for its current most recently completed taxable year or in the foreseeable futureyear.

Appears in 1 contract

Samples: Sales Agreement (SOPHiA GENETICS SA)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus, and the Final Prospectus, the Company does not expect to be treated as a passive foreign investment company (a “PFIC”), as defined in Section section 1297 of the Code) Code for its the current taxable year or in and the Company does not expect to be treated as a PFIC for the foreseeable future.

Appears in 1 contract

Samples: Atotech LTD

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2023.

Appears in 1 contract

Samples: Deposit Agreement (Ascendis Pharma a/S)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2016.

Appears in 1 contract

Samples: Deposit Agreement (Ascendis Pharma a/S)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2019.

Appears in 1 contract

Samples: Deposit Agreement (Ascendis Pharma a/S)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does not expect to be believe it was a passive foreign investment company (company, as defined in Section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current the taxable year or in the foreseeable futureended on December 31, 2020.

Appears in 1 contract

Samples: Open Market Sale (Gamida Cell Ltd.)

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Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (a “PFIC”), as defined in Section section 1297 of the Code) for its current taxable Code in any tax year ended on or in the foreseeable futurebefore December 31, 2017.

Appears in 1 contract

Samples: Letter Agreement (Cision Ltd.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company does not expect to be it was treated as, for the taxable year ending December 31, 2017, a passive foreign investment company (as defined in Section 1297 of the Code) for its current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Cowen and Company (Orchard Rx LTD)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth other than as disclosed in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company should not be characterized as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the Code for its most recently completed taxable year and the Company does not expect to be a passive foreign investment company (as defined in Section 1297 of the Code) PFIC for its current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Underwriting Agreement (Fidelis Insurance Holdings LTD)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2017.

Appears in 1 contract

Samples: Underwriting Agreement (Ascendis Pharma a/S)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing General Disclosure Package and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2020.

Appears in 1 contract

Samples: Underwriting Agreement (Ascendis Pharma a/S)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company does not expect to be it was treated as, for the taxable year ending December 31, 2018, a passive foreign investment company (as defined in Section 1297 of the Code) for its current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Orchard Therapeutics PLC

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company believes that it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the Code for its most recently completed taxable year and the Company does not expect to be a passive foreign investment company (as defined in Section 1297 of PFIC for the Code) for its current taxable year or in the foreseeable futureending December 31, 2021.

Appears in 1 contract

Samples: Underwriting Agreement (SOPHiA GENETICS SA)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does not expect to be it was treated as, for the taxable year ending December 31, 2019, a passive foreign investment company (as defined in Section 1297 of the Code) for its current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Sales Agreement (Orchard Therapeutics PLC)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package and the Final Prospectus, the Company does not expect to be believe it was a passive foreign investment company (a “PFIC”) for its previous taxable year and it does not expect to be classified as defined in Section 1297 of the Code) a PFIC for its current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Secoo Holding LTD

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2016.

Appears in 1 contract

Samples: Ascendis Pharma a/S

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does not expect to be believe that it was a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureended December 31, 2017.

Appears in 1 contract

Samples: Sales Agreement (Ascendis Pharma a/S)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does expects that it should not expect to be treated as a passive foreign investment company (company, as defined in Section section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its the current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Underwriting Agreement (PERRIGO Co PLC)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does not expect to be believe it was a passive foreign investment company (company, as defined in Section 1297 of the Code) Internal Revenue Code of 1986, as amended, for its current the taxable year or in the foreseeable futureended on December 31, 2022.

Appears in 1 contract

Samples: Open Market Sale (Gamida Cell Ltd.)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Statement and the Final Prospectus, the Company does not expect to be it was treated as, for the taxable year ending December 31, 2021, a passive foreign investment company (as defined in Section 1297 of the Code) for its current taxable year or in the foreseeable future.

Appears in 1 contract

Samples: Sales Agreement (Orchard Therapeutics PLC)

Passive Foreign Investment Company. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Pricing Disclosure Package Preliminary Prospectus and the Final Prospectus, the Company does believes that its shares should not expect to be treated as stock of a passive foreign investment company (a “PFIC”), as defined in Section section 1297 of the Code) for its current taxable year or in the foreseeable futureInternal Revenue Code of 1986, as amended.

Appears in 1 contract

Samples: Underwriting Agreement (Novocure LTD)

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