Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. The Company believes that it will not be considered a “passive foreign investment company” within the meaning of Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for the calendar year 2003.

Passive Foreign Investment Company. The Company believes that it is not, and after giving effect to the issuance and sale of the Securities as herein contemplated will not be considered be, a “"passive foreign investment company” within the meaning of " as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for (the calendar year 2003"CODE").

Passive Foreign Investment Company. The Company believes that does not believe it will not be considered is a “"passive foreign investment company” within the meaning of " (a "PFIC") as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amendedamended (the "Code"), and the regulations promulgated thereunder, for 2006, and does not expect to be classified as a PFIC in the calendar year 2003foreseeable future.

Passive Foreign Investment Company. The Company believes that it will is not, and does not be considered expect to become, a “passive foreign investment company” within the meaning of as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for and the calendar year 2003regulations promulgated thereunder. The Company intends to conduct its business in a manner such that it will not become a PFIC in the future under current laws and regulations.

Passive Foreign Investment Company. The After due inquiry, the Company believes that it will does not expect to be considered a “"passive foreign investment company” " within the meaning of Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for in the calendar current taxable year 2003or in future years.

Passive Foreign Investment Company. The Company believes that it will is not be considered and does not expect to become, a “passive foreign investment company” company within the meaning of Section section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for 1986 and the calendar year 2003regulations promulgated thereunder.

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 that does not believe it will not be considered was a “passive foreign investment company” within the meaning of (as defined in Section 1297 of the U.S. Internal Revenue Code of 1986Code, as amended, and the regulations and published regulations thereunder) for the calendar its taxable year 2003ended December 31, 2020.

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 that does not believe it will not be considered was a “passive foreign investment company” within the meaning of (as defined in Section 1297 of the U.S. Internal Revenue Code of 1986Code, as amended, and the regulations and published regulations thereunder) for the calendar its taxable year 2003ended December 31, 2021.

Passive Foreign Investment Company. The Company believes that it will is not, and does not be considered expect to become, a “passive foreign investment company” within the meaning of as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for and the calendar year 2003regulations promulgated thereunder.

Passive Foreign Investment Company. The Company believes does not believe that it will not be considered was a “passive foreign investment company” within the meaning of Section 1297 of the U.S. Internal Revenue Code of 1986, as amended, for its 2016 taxable year and does not expect to be a “passive foreign investment company” for its current taxable year or in the calendar year 2003foreseeable future.

Passive Foreign Investment Company. The Company believes does not believe that it will not be considered was a “passive foreign investment company,” within as such term is defined in the meaning of Section 1297 of the U.S. Internal Revenue Code of 1986, as amendedamended (the “Code”), for the calendar last completed fiscal year 2003for which audited financial statements of the Company have been filed with the Commission.

Passive Foreign Investment Company. The Company believes that does not believe it will not be considered is a “passive foreign investment company” within the meaning of (a “PFIC”) as defined in Section 1297 of the U.S. Internal Revenue Code of 1986, as amendedamended (the “Code”), and the regulations promulgated thereunder, for 2006, and does not expect to be classified as a PFIC in the calendar year 2003foreseeable future.

Passive Foreign Investment Company. The Company Company, based ---------------------------------- on its current operations and assets and taking into consideration the proceeds of the offering, believes that it will is not be considered a “passive foreign investment company” company (a "PFIC") within the meaning of Section 1297 1291 et seq. of the U.S. United States Internal Revenue Code of 1986, as amendedamended (the "Code"), for the calendar year 2003and is not likely to become a PFIC.