PFIC Status. The Company does not believe that it is a “passive foreign investment company” within the meaning of Section 1297 of the Code (a “PFIC”), for its current taxable year, and, based on its currently anticipated method of operation, the Company does not expect to become a PFIC in the future.
Appears in 3 contracts
Samples: Underwriting Agreement (Carnival PLC), Selling Agreement (Carnival PLC), Underwriting Agreement (Carnival PLC)
PFIC Status. The Based on management estimates and projections of future operations and revenue, the Company does not believe that it is will be a “passive foreign investment company” within the meaning of (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended (a the “PFICCode”), for its current taxable year, and, based on its currently anticipated method of operation, the Company year and does not expect to become a PFIC in the foreseeable future.
Appears in 3 contracts
Samples: Underwriting Agreement (Kosmos Energy Ltd.), Underwriting Agreement (Kosmos Energy Ltd.), Underwriting Agreement (Kosmos Energy Ltd.)
PFIC Status. The Company does not believe that it is a “passive foreign investment company” within Based on the meaning of Section 1297 of the Code (a “PFIC”)Company’s current projected income, for its current taxable year, and, based on its currently anticipated method of operationassets and activities, the Company does not expect to become a PFIC be treated as “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the futureUnited States Internal Revenue Code of 1986, as amended (the “Code”), for the current taxable year or for any future taxable year.
Appears in 2 contracts
Samples: Underwriting Agreement (Nord Anglia Education, Inc.), Underwriting Agreement (Nord Anglia Education, Inc.)
PFIC Status. The Based on the Company’s financial statements and the projected composition of its income and valuation of its assets, including goodwill, the Company does not believe that it is expect to be classified as a “passive foreign investment company” within the meaning of (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code (a “PFIC”)of 1986, as amended, for its current taxable year, and, based on its currently anticipated method of operation, the Company does not expect to become a PFIC year or in the foreseeable future.
Appears in 1 contract
Samples: Underwriting Agreement (500.com LTD)
PFIC Status. The Based on the Company’s current projected income, assets and activities, the Company does not believe that it is expect to be classified as a “passive foreign investment company” within the meaning of (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code (a “PFIC”)of 1986, as amended, for its current the taxable yearyear ending December 31, and, based on its currently anticipated method of operation, 2010 and the Company does not expect to become a PFIC in the foreseeable future.
Appears in 1 contract
Samples: Underwriting Agreement (Global Education & Technology Group LTD)
PFIC Status. The Based on the composition of the Company’s income and assets, the Company does not believe that it is expect to be a “passive foreign investment company” within the meaning of as defined in Section 1297 of the United States Internal Revenue Code (a “PFIC”)of 1986, as amended, for its current taxable year, and, based on its currently anticipated method of operation, the Company does not expect to become a PFIC year or in the foreseeable future.
Appears in 1 contract
PFIC Status. The Company does not believe that it is was a “passive foreign investment company” within the meaning of (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code (a “PFIC”)of 1986, as amended, for its current most recently completed taxable year, and, based on its currently anticipated method management estimates and projections of operationfuture operations and revenue, the Company does not believe that it will be a PFIC for its current taxable year and does not expect to become a PFIC in the foreseeable future.
Appears in 1 contract
Samples: Underwriting Agreement (Iroko Pharmaceuticals Inc.)
PFIC Status. The Company does not believe that it is was a “passive foreign investment company” within the meaning of (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code (a “PFIC”)of 1986, as amended, for its current most recently completed taxable year, and, based on its currently anticipated method management’s current estimates and projections of operationfuture operations and revenue, the Company does not believe that it will be a PFIC for its current taxable year and does not expect to become a PFIC in the foreseeable future.
Appears in 1 contract
PFIC Status. The Company does not believe that it is should be classified as a “passive foreign investment company” within the meaning of (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code (a “PFIC”)of 1986, as amended, for its current most recently completed taxable year, year and, based on its currently anticipated method of operationthe Company’s current projected income, assets and activities, the Company does not expect to become be classified as a PFIC in for the current year or for the foreseeable future.
Appears in 1 contract
Samples: International Underwriting and Placement Agreement (Banco Santander (Brasil) S.A.)
PFIC Status. The Based on the Company’s current and projected income, assets and activities, the Company does not believe that it is expect to be classified as a “passive foreign investment company” within the meaning of as defined in Section 1297 of the United States Internal Revenue Code (a “PFIC”)of 1986, as amended, for its current taxable yearyear ending December 31, and, based on its currently anticipated method of operation, the Company does not expect to become a PFIC 2011 or in the foreseeable future.
Appears in 1 contract