Common use of PFIC Clause in Contracts

PFIC. Based on current information and the current plans and expectations of the Company regarding the value and nature of its assets and the source and nature of its income, the Company believes that it will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297(a) of the United States Internal Revenue Code of 1986, as amended, for its taxable year ending December 31, 2019 and does not expect to be a PFIC in the foreseeable future.

PFIC. Based on upon the Company's current information and the current plans expected income and expectations of the Company regarding the value assets, including goodwill and nature of its assets and the source and nature of its incomeother unbooked intangibles, the Company believes that it will does not expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297(a) of the United States Internal Revenue Code of 1986, as amended, for its the current taxable year ending December 31, 2019 and does not expect to be a PFIC in or the foreseeable future.

PFIC. Based on current information and the current plans and expectations of the The Company regarding the value and nature of its assets and the source and nature of its income, the Company believes that it will does not expect to be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the regulations and published interpretations thereunder for its taxable the year ending December 31, 2019 2010, and does not expect has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company becoming a PFIC in the foreseeable futurefuture under current laws and regulations.

PFIC. Based on current information and the current plans and expectations of the Company regarding the value and nature of its assets and the source and nature of its income, the Company believes that it will should not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297(a) of the United States Internal Revenue Code of 1986, as amended, for its taxable year ending December 31, 2019 2016 and does not expect to be a PFIC in the foreseeable future.