Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 or any future year.

Passive Foreign Investment Company. The To the Company’s knowledge, the Company believes it was not a “passive foreign investment company” (as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunder, ) (“PFIC”) for the its taxable year ended December 31, 2020; 2018 and the Company does not reasonably expect to be considered as such a PFIC for the taxable year ending December 31, 2021 2019 or any future yearthe foreseeable future.

Passive Foreign Investment Company. The To the Company’s knowledge, the Company believes it was not a “passive foreign investment company” (as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunder, ) (“PFIC”) for the its taxable year ended December 31, 2020; 2019 and the Company does not reasonably expect to be considered as such a PFIC for the taxable year ending December 31, 2021 2020 or any future yearthe foreseeable future.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; 2014, and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending ended December 31, 2021 2015 or any for future year.taxable years during the term of the Securities;

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereundernot, for the taxable year ended December 31, 2020; 2007, and upon the consummation of the transactions described herein and the Company application of the proceeds thereof, does not reasonably expect to be considered as such become for the taxable year ending December 31, 2021 or any future year2008, a passive foreign investment company within the meaning of Section 1297 of the Code.

Passive Foreign Investment Company. The To the Company’s knowledge, the Company believes it was not a “passive foreign investment company” (as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunder, ) (“PFIC”) for the its taxable year ended December 31, 2020; 2020 and the Company does not reasonably expect to be considered as such a PFIC for the taxable year ending December 31, 2021 or any future yearthe foreseeable future.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 20202014; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 2015 or any future year.

Passive Foreign Investment Company. The Company believes that it was not a Passive Foreign Investment Company (“passive foreign investment company” as defined in PFIC”) within the meaning of Section 1297 of the Code and Code, during the regulations promulgated thereunder, for the taxable prior tax year ended on December 31, 2020; 2017, and based on current business plans and financial expectations, the Company does expects that it will not reasonably expect to be considered as such a PFIC for the taxable current tax year ending December 31, 2021 or any future yearand expects that it will not be a PFIC for the foreseeable future.

Passive Foreign Investment Company. The As of the date hereof, the Company believes believes, after due inquiry, and based on its correct operations and expected financial results, that it was will not constitute a “passive foreign investment company,” as such term is defined in Section 1297 the Internal Revenue Code of 1986, as amended (the Code and the regulations promulgated thereunder“Code”), for the taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the its current taxable year ending December 31, 2021 or any future year2010 and for its subsequent taxable year ending December 31, 2011.

Passive Foreign Investment Company. The After reasonable inquiry, the Company believes does not believe it was not should be classified as a “passive foreign investment company” as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, for the taxable year ended December 31, 20202013; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 2014 or any future year.

Passive Foreign Investment Company. The Company believes it was is not for the taxable year ended December 31, 2006, and, after giving effect to the offering and sale of the Shares and the application of the proceeds thereof, does not expect to become, a “passive foreign investment company” as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 or any future year.

Passive Foreign Investment Company. The Based on the projected composition of the Company’s income and fair market value of its assets, the Company believes it was does not expect to be a “passive foreign investment company” (as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunder, ) for the its taxable year ended December March 31, 2020; and 2020 or the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 or any future yearforeseeable future.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; 2016, and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending ended December 31, 2021 2017 or any for future year.taxable years during the term of the Securities;

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; 2015, and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending December 31, 2021 or any future year2016.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, for the taxable year ended December 31, 20202010; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 2011 or any future year.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” company (“PFIC”) as defined in under Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; 2014, and the Company does not reasonably expect to be considered as such for a PFIC in the current taxable year ending December 31, 2021 2015, or any future yearin the foreseeable future.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; 2017, and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending ended December 31, 2021 2018 or any for future year.taxable years during the term of the Securities;

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; , and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending ended December 31, 2021 or any for future year.taxable years during the term of the Securities;

Passive Foreign Investment Company. The Based on the Company’s current estimates and certain assumptions with respect to the characterization of its gross income and its gross assets, and the nature of its business and its current business plan, the Company believes does not believe it was not a “passive foreign investment company” (as defined in Section 1297 of the Code and the regulations promulgated thereunder, Code) for the its taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 or any future year2022.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; 2019, and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending ended December 31, 2021 2020 or any for future year.taxable years during the term of the Securities;

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 20202013; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 2014 or any future year.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; 2013, and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending ended December 31, 2021 2014 or any for future year.taxable years during the term of the Securities;

Passive Foreign Investment Company. The Based on the information available to the Company at the time of the filing of the Form 20-F dated April 28, 2023, the Company believes that it was not a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the Company’s taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 or any future year2022.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Internal Revenue Code and the regulations promulgated thereunderof 1986, as amended (a “PFIC”), for the its taxable year ended December 31, 2020; 2011, and the Company it does not reasonably expect to be considered as such a PFIC for the its taxable year ending ended December 31, 2021 2012 or any for future year.taxable years during the term of the Securities;

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” company (“PFIC”) as defined in under Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; 2013, and the Company does not reasonably expect to be considered as such for a PFIC in the current taxable year ending December 31, 2021 2014, or any future yearin the foreseeable future.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 20202017; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 2018 or any future year.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 20202019; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 2020 or any future year.

Passive Foreign Investment Company. The Company believes it was does not expect to be a “passive foreign investment company” as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 or any future year.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” company (“PFIC”) as defined in under Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; 2017, and the Company does not reasonably expect to be considered as such for a PFIC in the current taxable year ending December 31, 2021 2018, or any future yearin the foreseeable future.

Passive Foreign Investment Company. The Company believes expects that it was not classified as a “"passive foreign investment company” " as defined in Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; and the Company does not reasonably expect to be considered as such for the taxable year ending December 31, 2021 or any future year2021.

Passive Foreign Investment Company. The Company believes it was is not a “passive foreign investment company” as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; and 2009, nor does the Company does not reasonably expect to be so considered as such for the taxable year ending ended December 31, 2021 2010 or any future year.

Passive Foreign Investment Company. The Company believes it was not a “passive foreign investment company” company (“PFIC”) as defined in under Section 1297 of the Code and the regulations promulgated thereunder, for the taxable year ended December 31, 2020; 2021, and the Company does not reasonably expect to be considered as such for a PFIC in the current taxable year ending December 31, 2021 2022, or any future yearin the foreseeable future.