CFC. Giving effect to the transactions contemplated by this Agreement and the other Transaction Agreements, none of the Group Companies is, or expects to become, a “Controlled Foreign Corporation (CFC)” within the meaning of Section 957 of the Code. For United States tax classification purposes the Company is classified as an association taxable as a corporation pursuant to Section 301.7701-2 of the Regulations. No election has been made under Section 301.7701-3 of the Regulations to treat the Company or any Group Company as a partnership or disregarded entity for United States Tax purposes.
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Sources: Option and Series D+ Preference Shares Purchase Agreement (LinkDoc Technology LTD), Series D+ Preference Shares Subscription Agreement (LinkDoc Technology LTD)