PFIC Status. The Company does not believe it is a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1296 of the United States Internal Revenue Code of 1986, as amended, and does not believe it is likely to become a PFIC.
Appears in 33 contracts
Sources: Underwriting Agreement (ATLAS CRITICAL MINERALS Corp), Underwriting Agreement (ATLAS CRITICAL MINERALS Corp), Underwriting Agreement (BrilliA Inc)
PFIC Status. The Company does not believe that it is a Passive Foreign Investment Company (“PFIC”) passive foreign investment company” within the meaning of Section 1296 1297 of the United States Internal Revenue Code (a “PFIC”), for its current taxable year, and, based on its currently anticipated method of 1986operation, as amended, and the Company does not believe it is likely expect to become a PFICPFIC in the future.
Appears in 3 contracts
Sources: Underwriting Agreement (Carnival PLC), Selling Agreement (Carnival PLC), Underwriting Agreement (Carnival PLC)
PFIC Status. The Company does not believe it is a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1296 1297 of the United States Internal Revenue Code of 1986, as amended, and does not believe it is likely to become a PFIC.
Appears in 2 contracts
Sources: Securities Purchase Agreement (Belite Bio, Inc), Securities Purchase Agreement (Belite Bio, Inc)
PFIC Status. The Company does not believe it is was a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1296 1297(a) of the United States Internal Revenue Code of 1986, as amended, for its taxable year ended March 31, 2010 and it does not believe it is likely expect to become be a PFICPFIC in the foreseeable future.
Appears in 2 contracts
Sources: Underwriting Agreement (Funtalk China Holdings LTD), Underwriting Agreement (Funtalk China Holdings LTD)
PFIC Status. The Company does not believe believes that it is not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1296 1297 of the United States Internal Revenue Code of 1986, as amended, and does not believe it is likely expect to become a PFICPFIC in the foreseeable future.
Appears in 1 contract
Sources: u.s. Underwriting Agreement (Vista Oil & Gas, S.A.B. De C.V.)
PFIC Status. The Company does not believe it is a Passive Foreign Investment Company passive foreign investment company (a “PFIC”) within the meaning of Section 1296 1297 of the United States Internal Revenue Code of 1986, as amended, amended (the “Internal Revenue Code”) and does expects to continue its operations in such a manner that it will not believe it is likely to become be a PFIC.
Appears in 1 contract
Sources: International Underwriting Agreement (Toyota Motor Corp/)
PFIC Status. The Company does not believe that it is qualified as a Passive Foreign Investment Company “passive foreign investment company” (“PFIC”) within the meaning of Section 1296 of the United States Internal Revenue Code of 1986, as amended, for its most recently completed taxable year and does not believe that it is likely to become a PFICPFIC in a subsequent taxable year.
Appears in 1 contract