Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. The Company believes that it will not be considered for the current year or in the foreseeable future a “passive foreign investment company” (“PFIC”) as defined in Section 1296 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”) or a “foreign personal holding company” within the meaning of Section 552 of the Code.

Passive Foreign Investment Company. The Company believes that it will not be considered for the current year or in the foreseeable future a “passive foreign investment company” (“PFIC”) as defined in within the meaning of Section 1296 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, for the “Code”) or a “foreign personal holding company” within the meaning of Section 552 of the Codecalendar year 2003.

Passive Foreign Investment Company. The Company believes does not believe that it will not be considered for the current year or in the foreseeable future was a “passive foreign investment company” (“PFIC”) as defined in within the meaning of Section 1296 1297 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”) or amended, for its 2016 taxable year and does not expect to be a “passive foreign personal holding investment company” within for its current taxable year or in the meaning of Section 552 of the Codeforeseeable future.

Passive Foreign Investment Company. The Company believes that does not believe it will not be considered for the current year or in the foreseeable future is a “"passive foreign investment company” " (“a "PFIC”") as defined in Section 1296 1297 of the U.S. Internal Revenue Code of 1986, as amended (the “"Code”) or "), and the regulations promulgated thereunder, for 2006, and does not expect to be classified as a “foreign personal holding company” within PFIC in the meaning of Section 552 of the Codeforeseeable future.

Passive Foreign Investment Company. The Company believes does not believe that it will not be considered for the current year or in the foreseeable future was 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”) or a “foreign personal holding company” within ), for the meaning of Section 552 last completed fiscal year for which audited financial statements of the CodeCompany have been filed with the Commission.

Passive Foreign Investment Company. The Company believes that it will is not, and does not be considered for the current year or in the foreseeable future expect to become, a “passive foreign investment company” (“PFIC”) as defined in Section 1296 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, and the “Code”) or a “foreign personal holding company” within the meaning of Section 552 of the Coderegulations promulgated thereunder.

Passive Foreign Investment Company. The Company believes that does not believe it will not be considered for the current year or in the foreseeable future is a “passive foreign investment company” (a “PFIC”) as defined in Section 1296 1297 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”) or ), and the regulations promulgated thereunder, for 2006, and does not expect to be classified as a “foreign personal holding company” within PFIC in the meaning of Section 552 of the Codeforeseeable future.

Passive Foreign Investment Company. The Company believes that it will is not, and does not be considered for the current year or in the foreseeable future expect to become, a “passive foreign investment company” (“PFIC”) as defined in Section 1296 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, and the “Code”) or regulations promulgated thereunder. The Company intends to conduct its business in a “foreign personal holding company” within manner such that it will not become a PFIC in the meaning of Section 552 of the Codefuture under current laws and regulations.

Passive Foreign Investment Company. The Company believes that it will is not be considered for the current year or in the foreseeable future and does not expect to become, a “passive foreign investment company” (“PFIC”) as defined in Section 1296 company within the meaning of section 1297 of the U.S. Internal Revenue Code of 1986, as amended (1986 and the “Code”) or a “foreign personal holding company” within the meaning of Section 552 of the Coderegulations promulgated thereunder.

Passive Foreign Investment Company. The 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 nature of its business and its current business plan, the Company believes that does not believe it will not be considered for the current year or in the foreseeable future was a “passive foreign investment company” (“PFIC”) as defined in Section 1296 1297 of the U.S. Internal Revenue Code of 1986Code, as amended (amended, and the “Code”regulations and published regulations thereunder) or a “foreign personal holding company” within the meaning of Section 552 of the Codefor its taxable year ended December 31, 2021.

Passive Foreign Investment Company. The After due inquiry, the Company believes that it will does not expect to be considered for the current year or in the foreseeable future a “"passive foreign investment company” (“PFIC”) as defined in " within the meaning of Section 1296 1297 of the U.S. Internal Revenue Code of 1986, as amended (amended, in the “Code”) current taxable year or a “foreign personal holding company” within the meaning of Section 552 of the Codein future years.

Passive Foreign Investment Company. The 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 nature of its business and its current business plan, the Company believes that does not believe it will not be considered for the current year or in the foreseeable future was a “passive foreign investment company” (“PFIC”) as defined in Section 1296 1297 of the U.S. Internal Revenue Code of 1986Code, as amended (amended, and the “Code”regulations and published regulations thereunder) or a “foreign personal holding company” within the meaning of Section 552 of the Codefor its taxable year ended December 31, 2020.