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 29 contracts
Samples: Underwriting Agreement (BrilliA Inc), Sales Agreement (Foresight Autonomous Holdings Ltd.), Securities Purchase Agreement (Bos Better Online Solutions LTD)
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
Samples: 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 passive foreign investment company (“PFIC”) and does not expect that it will be treated as a 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 for its current taxable year. The Company has no plan or intention to become operate in such a PFICmanner that would reasonably be expected to result in the Company becoming a PFIC in future taxable years.
Appears in 1 contract
Samples: At the Market Offering Agreement (Edesa Biotech, Inc.)
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
Samples: 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
Samples: 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.
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