Common use of PFIC and CFC Clause in Contracts

PFIC and CFC. The Company expects not to be a “passive foreign investment company” within the meaning of Section 1297 of the Code for its current taxable year ending December 31, 2024, or for the foreseeable future. The Company is not a “controlled foreign corporation”, as defined in Section 957 of the Code.

PFIC and CFC. The Company expects not to be a “passive foreign investment company” within the meaning of Section 1297 of the Code for its current taxable year ending December 31, 20242023, or for the foreseeable future. The Company is not a “controlled foreign corporation”, as defined in Section 957 of the Code.

PFIC and CFC. The Company expects not to be a “passive foreign investment company” within the meaning of Section 1297 of the Code for its current taxable year ending December 31, 20242020, or for the foreseeable future. The Company is not a “controlled foreign corporation”, as defined in Section 957 of the Code.

PFIC and CFC. The Company expects not to be a “passive foreign investment company” within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year ending December 31, 20242020, or for the foreseeable future. The Company is not a “controlled foreign corporation”, as defined in Section 957 the Internal Revenue Code of the Code1986, as amended.

PFIC and CFC. The Company expects not to be a “passive foreign investment company” within the meaning of Section 1297 of the Code for its current taxable year ending December 31, 20242023, or for the foreseeable future. The Company is not a “controlled foreign corporation”, as defined in Section 957 of the Code.