PFIC. The Company is not a "passive foreign investment company" within the meaning of Section 1297 of the Code.
Appears in 4 contracts
Samples: Share Purchase Agreement (El Sitio Inc), Share Purchase Agreement (El Sitio Inc), Share Purchase Agreement (El Sitio Inc)
PFIC. The Company is not a "“passive foreign investment company" ” within the meaning of Section 1297 of the CodeU.S. Internal Revenue Code of 1986, as amended.
Appears in 2 contracts
Samples: Share Purchase Agreement (Juno Therapeutics, Inc.), Share Purchase Agreement (Juno Therapeutics, Inc.)
PFIC. The Company is not a "“passive foreign investment company" ” within the meaning of Section 1297 of the Code.
Appears in 1 contract
Samples: Merger Agreement (KIT Digital, Inc.)
