PFIC. Based on the Company’s current income and asset and projections as to the value of its assets and market value of its ADSs, including the current and anticipated value of its assets, the Company believes that it was not and does not expect to be a “passive foreign investment company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended for the current taxable year or in foreseeable future.
Appears in 7 contracts
Samples: Convertible Note Purchase Agreement (Uxin LTD), Convertible Note Purchase Agreement (Uxin LTD), Convertible Note Purchase Agreement (Uxin LTD)