PFIC Status. Based upon the Company’s current and expected income and assets, including goodwill (taking into account the expected proceeds from this offering) and projections as to the market price of the ADSs following the offering, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the current taxable year or the foreseeable future.
Appears in 5 contracts
Samples: Underwriting Agreement (Jianzhi Education Technology Group Co LTD), Underwriting Agreement (Jianzhi Education Technology Group Co LTD), Underwriting Agreement (Futu Holdings LTD)
PFIC Status. Based upon the Company’s current and expected projected income and assets, including goodwill (taking into account the expected proceeds from this offering) , and projections as to the market expected price of the ADSs following the in this offering, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the its current taxable year or the foreseeable future.;
Appears in 2 contracts
Samples: Underwriting Agreement (KE Holdings Inc.), KE Holdings Inc.
PFIC Status. [Based upon the Company’s current and expected income and assets, including goodwill assets (taking into account the expected proceeds from this offering) ), including goodwill and other unbooked intangibles and projections as to the market price of the Company’s ADSs following the offering, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for the its current taxable year or in the foreseeable future.]
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PFIC Status. Based upon the expected composition of the Company’s current and expected income and assets, including goodwill (taking into account assets and the expected proceeds from this offering) and projections as to value of its assets (including goodwill, which is based on the expected market price of the ADSs following the offering), the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the current taxable year or the foreseeable futureyear.
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PFIC Status. Based upon on the Company’s current and expected income and assets, including goodwill (taking into account the expected proceeds from this offering) assets and projections as to the market price value of the ADSs following the offeringits ADSs, the Company does not expect to be a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the its current taxable year or in the foreseeable future.
Appears in 1 contract
Samples: Underwriting Agreement (iClick Interactive Asia Group LTD)
PFIC Status. Based upon the Company’s current and expected projected income and assets, including goodwill (taking into account the expected proceeds from this offering) , and projections as to the market price of the its ADSs immediately following the this offering, the Company does not expect to be a “passive foreign investment company” company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the its current taxable year or the foreseeable future.
Appears in 1 contract
Samples: Underwriting Agreement (So-Young International Inc.)
PFIC Status. Based upon the Company’s current and expected income and assets, including goodwill (taking into account the expected proceeds from this offering) and projections as to the market price of the ADSs following the offering, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the current taxable year or the foreseeable future...
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PFIC Status. Based upon on the Company’s current projected income, assets and expected income and assets, including goodwill (taking into account the expected proceeds from this offering) activities and projections as to the value of the Company’s assets based on the market price value of the ADSs following the offeringand Ordinary Shares, the Company does not expect to be classified as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the its current taxable year or in the foreseeable future.
Appears in 1 contract
Samples: Underwriting Agreement (ChinaCache International Holdings Ltd.)