Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. The Company does not believe that it was a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes for the taxable year ended December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year.

Passive Foreign Investment Company. The Company does not believe that believes it was not a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 2020; and it the Company does not reasonably expect to be treated considered as a PFIC such for the current taxable year ending December 31, 2021 or any future year.

Passive Foreign Investment Company. The As of the date hereof, the Company does not believe believes, after due inquiry, and based on its current operations and expected financial results, that it was will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “PFICCode”) ), for U.S. federal income tax purposes for the its current taxable year ended ending December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2013.

Passive Foreign Investment Company. The To the Company’s knowledge, the Company does was not believe that it was a “passive foreign investment company” (as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunder) (“PFIC”) for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2020 and it does not expect to be treated as a PFIC for the current taxable yearyear ending December 31, 2021 or the foreseeable future.

Passive Foreign Investment Company. The Based on the information available to the Company does not believe at the time of the filing of the Form 20-F dated April 28, 2023, the Company believes that it was not a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code for the Company’s taxable year ended December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2022.

Passive Foreign Investment Company. The As of the date hereof, the Company does not believe believes, after due inquiry, and based on its correct operations and expected financial results, that it was will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “PFICCode”) ), for U.S. federal income tax purposes for the its current taxable year ended ending December 31, 2023 2010 and it does not expect to be treated as a PFIC for the current its subsequent taxable yearyear ending December 31, 2011.

Passive Foreign Investment Company. The Company does not believe that it was a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes not, for the taxable year ended December 31, 2023 2007, and it upon the consummation of the transactions described herein and the application of the proceeds thereof, does not expect to be treated as a PFIC become for the current taxable yearyear ending December 31, 2008, a passive foreign investment company within the meaning of Section 1297 of the Code.

Passive Foreign Investment Company. The Company does not believe that believes it was not a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 2014; and it the Company does not reasonably expect to be treated considered as a PFIC such for the current taxable year ending December 31, 2015 or any future year.

Passive Foreign Investment Company. The Based on the information available to the Company does not believe at the time of the filing of the Form 20-F dated March 28, 2024, the Company believes that it was not a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code for the Company’s taxable year ended December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2023.

Passive Foreign Investment Company. The To the Company’s knowledge, the Company does was not believe that it was a “passive foreign investment company” (as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunder) (“PFIC”) for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2019 and it does not expect to be treated as a PFIC for the current taxable yearyear ending December 31, 2020 or the foreseeable future.

Passive Foreign Investment Company. The Company does not believe believes that it was not a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) for U.S. federal income within the meaning of Section 1297 of the Code, during the prior tax purposes for the taxable year ended on December 31, 2023 2017, and based on current business plans and financial expectations, the Company expects that it does will not expect to be treated as a PFIC for the current taxable yeartax year and expects that it will not be a PFIC for the foreseeable future.

Passive Foreign Investment Company. The To the Company’s knowledge, the Company does was not believe that it was a “passive foreign investment company” (as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunder) (“PFIC”) for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2018 and it does not expect to be treated as a PFIC for the current taxable yearyear ending December 31, 2019 or the foreseeable future.

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2014, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2015 or for future taxable years during the current taxable year.term of the Securities;

Passive Foreign Investment Company. The Company does is not believe that it was a “passive foreign investment company” (“PFIC”) for as defined in Section 1297 of the U.S. federal income tax purposes Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 and it 2009, nor does not the Company expect to be treated as a PFIC so considered for the current taxable year ended December 31, 2010 or any future year.

Passive Foreign Investment Company. The Company does not believe that believes it was not a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 2013; and it the Company does not reasonably expect to be treated considered as a PFIC such for the current taxable year ending December 31, 2014 or any future year.

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2016, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2017 or for future taxable years during the current taxable year.term of the Securities;

Passive Foreign Investment Company. The Company does not believe that believes it was not a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 2017; and it the Company does not reasonably expect to be treated considered as a PFIC such for the current taxable year ending December 31, 2018 or any future year.

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2019, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2020 or for future taxable years during the current taxable year.term of the Securities;

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2017, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2018 or for future taxable years during the current taxable year.term of the Securities;

Passive Foreign Investment Company. The Company does is not believe that it was a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes for the taxable year ended December 31, 2023 2006, and, after giving effect to the offering and it sale of the Shares and the application of the proceeds thereof, does not expect to be treated become, a “passive foreign investment company” as a PFIC for defined in Section 1297 of the current taxable yearU.S. Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder.

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2024, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2025 or for future taxable years during the current taxable year.term of the Securities;

Passive Foreign Investment Company. The After reasonable inquiry, the Company does not believe that it was should be classified as a “passive foreign investment company” (“PFIC”) for as defined in Section 1297 of the U.S. federal income tax purposes Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 2013; and it the Company does not expect to be treated considered as a PFIC such for the current taxable year ending December 31, 2014 or any future year.

Passive Foreign Investment Company. The As of the date hereof, the Company does not believe believes, after due inquiry, and based on its current operations and expected financial results, that it was will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “PFICCode”) ), for U.S. federal income tax purposes for the its current taxable year ended ending December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2015.

Passive Foreign Investment Company. The Company does not believe that believes it was not a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 2019; and it the Company does not reasonably expect to be treated considered as a PFIC such for the current taxable year ending December 31, 2020 or any future year.

Passive Foreign Investment Company. The Company does not believe that it was expect to be a “passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes as defined in Section 1297 of the Code for the taxable year ended December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2020.

Passive Foreign Investment Company. The Based on the estimated composition of its income and assets for its taxable year ended March 31, 2024, the Company does not believe believes that it was not a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the Code for U.S. federal income tax purposes for the its taxable year ended December March 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2024.

Passive Foreign Investment Company. The Company does not believe expects that it was not classified as a “"passive foreign investment company” (“PFIC”) for U.S. federal income tax purposes " as defined in Section 1297 of the Code for the taxable year ended ending December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2021.

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2020, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2021 or for future taxable years during the current taxable year.term of the Securities;

Passive Foreign Investment Company. The Company does not believe that believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2015, and it does not expect to be treated as a PFIC for the current its taxable yearyear ending December 31, 2016.

Passive Foreign Investment Company. The Company does not believe that believes it was not a “passive foreign investment company” (“PFIC”) for as defined in Section 1297 of the U.S. federal income tax purposes Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, for the taxable year ended December 31, 2023 2010; and it the Company does not reasonably expect to be treated considered as a PFIC such for the current taxable year ending December 31, 2011 or any future year.

Passive Foreign Investment Company. The As of the date hereof, the Company does not believe believes, after due inquiry, that it was will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “PFICCode”) for U.S. federal income tax purposes for the its current taxable year ended December 31ending February 28, 2023 2009 and it does not expect to be treated as a PFIC for the current its subsequent taxable yearyear ending February 28, 2010.

Passive Foreign Investment Company. The As of the date hereof, the Company does not believe believes, after due inquiry, and based on its current operations and expected financial results, that it was will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “PFICCode”) ), for U.S. federal income tax purposes for the its current taxable year ended ending December 31, 2023 and it does not expect to be treated as a PFIC for the current taxable year2014.

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2013, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2014 or for future taxable years during the current taxable year.term of the Securities;

Passive Foreign Investment Company. The Company does was not believe that it was a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code of 1986, as amended (a “PFIC”) ), for U.S. federal income tax purposes for the its taxable year ended December 31, 2023 2011, and it does not expect to be treated as a PFIC for its taxable year ended December 31, 2012 or for future taxable years during the current taxable year.term of the Securities;