Common use of PFIC Status Clause in Contracts

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this Agreement, including the current and anticipated valuation of its assets, the Company believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this AgreementAmerican Depositary Shares, including the current and anticipated valuation of its assets, the Company believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this AgreementClass A Ordinary Shares, including the current and anticipated valuation of its assets, the Company believes that does not believe it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year year, and does not expect to be become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares Offered Securities immediately following the public offering of its Shares Offered Securities contemplated under this Agreement, including the current and anticipated valuation of its assets, the Company believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this AgreementFirm Shares, including the current and anticipated valuation of its assets, the Company believes that does not believe it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year year, and does not expect to be become a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current and projected income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this AgreementADSs, including the current and anticipated valuation of its assets, the Company believes that it was not a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current and projected income and assets assets, and projections as to the value of its assets and the market value price of its Shares ADSs immediately following the public offering of its Shares contemplated under this Agreementoffering, including the current and anticipated valuation of its assets, the Company believes that it was not a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be a PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares ADSs immediately following the public offering of its Shares contemplated under this Agreementoffering, including the current and anticipated valuation of its assets, the Company believes that it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the current and anticipated value of the Company’s current assets and the composition of its income and assets and the composition of its income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this Agreement, including the current and anticipated valuation of its assetsAmerican Depositary Shares, the Company believes that it was does not expect to be treated as a Passive Foreign Investment Company passive foreign investment company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be PFIC for its current taxable year or in the foreseeable future.

PFIC Status. Based on the Company’s current income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this AgreementOrdinary Shares, including the current and anticipated valuation of its assets, the Company believes that does not believe it was not a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year year, and does not expect to be become a PFIC for its current taxable year or in the foreseeable futureyear.

PFIC Status. Based on the Company’s current and expected income and assets and projections as to the value of its assets and the market value of its Shares immediately following the public offering of its Shares contemplated under this AgreementAmerican Depositary Shares, including the current and anticipated valuation of its assets, the Company believes that it was not and does not expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year and does not expect to be a PFIC for its current taxable year or in the foreseeable future.