Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. As of the date hereof, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending December 31, 2013.

Passive Foreign Investment Company. As of the date hereof, the The Company believes, after due inquiry, and based on its current operations and expected financial results, that believes it will was not constitute a “passive foreign investment company,” as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (and the “Code”)regulations promulgated thereunder, for its current the taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 20132021 or any future year.

Passive Foreign Investment Company. As of the date hereof, the The Company believes, after due inquiry, and based on its current operations and expected financial results, believes that it will not constitute be considered a “passive foreign investment company,” as such term is defined in within the meaning of Section 1297 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”)amended, for its current taxable the calendar year ending December 31, 20132003.

Passive Foreign Investment Company. As Based on the information available to the Company at the time of the date hereoffiling of the Form 20-F dated April 28, 2023, the Company believes, after due inquiry, and based on its current operations and expected financial results, believes that it will was not constitute a “passive foreign investment company,” as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (for the “Code”), for its current Company’s taxable year ending ended December 31, 20132022.

Passive Foreign Investment Company. As Based on the composition of the date hereofits income and assets, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will was not constitute a “passive foreign investment companycompany (“PFIC”),” as such term is defined in the U.S. Internal Revenue Code of 1986, as amended (the “Code”), for its taxable year ending February 28, 2013 and, based on the projected composition of its income and assets, the Company does not expect that it will be a PFIC for the current taxable year ending December 31February 28, 20132014.

Passive Foreign Investment Company. As of the date hereof, the Company believes, after due inquiry, and based on its current correct operations and expected financial results, that it will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending December 31, 20132010 and for its subsequent taxable year ending December 31, 2011.

Passive Foreign Investment Company. As Based on the information available to the Company at the time of the date hereoffiling of the Form 20-F dated March 28, 2024, the Company believes, after due inquiry, and based on its current operations and expected financial results, believes that it will was not constitute a “passive foreign investment company,” as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (for the “Code”), for its current Company’s taxable year ending ended December 31, 20132023.

Passive Foreign Investment Company. As of the date hereof, the The Company believes, after due inquiry, and based on its current operations and expected financial results, believes that it will not constitute be considered for the current year or in the foreseeable future a “passive foreign investment company,” (“PFIC”) as such term is defined in Section 1296 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending December 31, 2013) or a “foreign personal holding company” within the meaning of Section 552 of the Code.

Passive Foreign Investment Company. As of the date hereof, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending December 31, 20132014.

Passive Foreign Investment Company. As Based on the estimated composition of the date hereofits income, assets and operations for 2023, the Company believes, after due inquiry, and based on its current operations and expected financial results, believes that it will was not constitute a “passive foreign investment company,” (“PFIC”) as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (for the “Code”), for its current taxable year ending December 31, 2013.2023. (fff)

Passive Foreign Investment Company. As The Company should not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the date hereof, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will not constitute a “passive foreign investment company,” as such term is defined in the United States Internal Revenue Code of 1986, as amended (the “Code”), for its current the taxable year ending December 31, 2013, and based on the Company’s current and expected assets, income and operations as described in the Registration Statement, the Time of Sale Prospectus and the Prospectus, the Company does not believe that it is likely to become a PFIC for any future tax year.

Passive Foreign Investment Company. As of the date hereof, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “Code”), ) for its current taxable year ending December 31February 28, 20132009 and for its subsequent taxable year ending February 28, 2010.

Passive Foreign Investment Company. As of the date hereof, the The Company believes, after due inquiry, and based on its current operations and expected financial results, expects that it will was not constitute classified as a “"passive foreign investment company,” " as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (for the “Code”), for its current taxable year ending December 31, 20132021.

Passive Foreign Investment Company. As Based on the projected composition of the date hereofCompany’s income and fair market value of its assets, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will does not constitute expect to be a “passive foreign investment company,” (as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (and the “Code”), regulations promulgated thereunder) for its current taxable year ending December ended March 31, 20132020 or the foreseeable future.

Passive Foreign Investment Company. As of the date hereof, the The Company believes, after due inquiry, and based on its current operations and expected financial results, that it will is not constitute a “passive foreign investment company,” as such term is defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, and the “Code”)regulations promulgated thereunder, for its current the taxable year ending ended December 31, 20132009, nor does the Company expect to be so considered for the taxable year ended December 31, 2010 or any future year.

Passive Foreign Investment Company. As of For the date hereoffiscal years ending March 31, 2011, and March 31, 2012, the Company believes, after due inquirywas not, and based on its current operations and expected financial resultsfor future fiscal years the Company does not expect to be, that it will not constitute a “passive foreign investment company,” as such term is defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending December 31, 2013amended.

Passive Foreign Investment Company. As of For the date hereoffiscal years ending March 31, 2012, and March 31, 2013, the Company believes, after due inquirywas not, and based on its current operations and expected financial resultsfor future fiscal years the Company does not expect to be, that it will not constitute a “passive foreign investment company,” as such term is defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending December 31, 2013amended.

Passive Foreign Investment Company. As Based on the Company’s current estimates and certain assumptions with respect to the characterization of its gross income and its gross assets, and the date hereofnature of its business and its current business plan, the Company believes, after due inquiry, and based on its current operations and expected financial results, that does not believe it will not constitute was a “passive foreign investment company,” (as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (the “Code”), ) for its current taxable year ending ended December 31, 20132022.

Passive Foreign Investment Company. As Based on the Company’s current estimates and certain assumptions with respect to the characterization of its gross income and its gross assets, and the date hereofnature of its business and its current business plan, the Company believes, after due inquiry, and based on its current operations and expected financial results, that does not believe it will not constitute was a “passive foreign investment company,” (as such term is defined in Section 1297 of the U.S. Internal Revenue Code of 1986Code, as amended (amended, and the “Code”), regulations and published regulations thereunder) for its current taxable year ending ended December 31, 20132021.

Passive Foreign Investment Company. As Based on the composition of the date hereofits income and assets, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will was not constitute a “passive foreign investment companycompany (“PFIC”),” as such term is defined in the U.S. Internal Revenue Code of 1986, as amended (the “Code”), for its taxable year ending February 29, 2012 and, based on the projected composition of its income and assets, the Company does not expect that it will be a PFIC for the current taxable year ending December 31February 28, 2013.

Passive Foreign Investment Company. As of the date hereofAfter reasonable inquiry, the Company believes, after due inquiry, and based on its current operations and expected financial results, that does not believe it will not constitute should be classified as a “passive foreign investment company,” as such term is defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, and the “Code”)regulations promulgated thereunder, for its current the taxable year ended December 31, 2013; and the Company does not expect to be considered as such for the taxable year ending December 31, 20132014 or any future year.

Passive Foreign Investment Company. As of the date hereof, the Company believes, after due inquiry, and based on its current operations and expected financial results, that it will not constitute a “passive foreign investment company,” as such term is defined in the Internal Revenue Code of 1986, as amended (the “Code”), for its current taxable year ending December 31, 20132015.

Passive Foreign Investment Company. As Based on the estimated composition of the date hereofits income, assets and operations for 2020, the Company believes, after due inquiry, and based on its current operations and expected financial results, believes that it will was not constitute a “passive foreign investment company,” (“PFIC”) as such term is defined in Section 1297 of the Internal Revenue Code of 1986, as amended (for the “Code”), for its current taxable year ending December 31, 20132020.

Passive Foreign Investment Company. As Based on the Company’s current estimates and certain assumptions with respect to the characterization of its gross income and its gross assets, and the date hereofnature of its business and its current business plan, the Company believes, after due inquiry, and based on its current operations and expected financial results, that does not believe it will not constitute was a “passive foreign investment company,” (as such term is defined in Section 1297 of the U.S. Internal Revenue Code of 1986Code, as amended (amended, and the “Code”), regulations and published regulations thereunder) for its current taxable year ending ended December 31, 20132020.

Passive Foreign Investment Company. As of the date hereof, the The Company believes, after due inquiry, and based on its current operations and expected financial results, that believes it will was not constitute a “passive foreign investment company,” as such term is defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, and the “Code”)regulations promulgated thereunder, for its current the taxable year ended December 31, 2010; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 20132011 or any future year.