Common use of PFIC Status Clause in Contracts

PFIC Status. Based on the past and projected composition of its income and assets, and the valuation of its assets, including goodwill, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 37 contracts

Sources: Securities Purchase Agreement (Jiuzi Holdings, Inc.), Securities Purchase Agreement (MingZhu Logistics Holdings LTD), Securities Purchase Agreement (Yueda Digital Holding)

PFIC Status. Based on the past Company’s current income and projected composition assets and projections as to the value of its income and assets, assets and the market value of its Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not expect to be believe it was a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

Appears in 27 contracts

Sources: Underwriting Agreement (J-Star Holding Co., Ltd.), Underwriting Agreement (J-Star Holding Co., Ltd.), Underwriting Agreement (J-Star Holding Co., Ltd.)

PFIC Status. Based on the past Company’s current income and projected composition assets and projections as to the value of its income and assets, assets and the market value of its Securities, including the current and anticipated valuation of its assets, including goodwill, the Company does not expect to be believe it was a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

Appears in 26 contracts

Sources: Underwriting Agreement (MEDI Group LTD), Underwriting Agreement (MEDI Group LTD), Underwriting Agreement (Ultratrex Inc.)

PFIC Status. Based on the past Company’s current income and projected composition assets and projections as to the value of its income and assets, assets and the market value of its Ordinary Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not expect to be believe it was a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its most recent taxable year, and does not expect to become a PFIC for its current taxable year or in the foreseeable future.

Appears in 15 contracts

Sources: Underwriting Agreement (Solar Strategy Holdings LTD), Underwriting Agreement (STAK Inc.), Underwriting Agreement (OneConstruction Group LTD)

PFIC Status. Based on the past and projected composition of its income and assets, and the valuation of its assets, including goodwill, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 7 contracts

Sources: Underwriting Agreement (OTSAW LTD), Underwriting Agreement (Youxin Technology LTD), Underwriting Agreement (Springview Holdings LTD)

PFIC Status. Based on the past management estimates and projected composition projections of its income future operations and assets, and the valuation of its assets, including goodwillrevenue, the Company does not expect to believe that it will be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its current taxable year or and does not expect to become a PFIC in the foreseeable future.

Appears in 3 contracts

Sources: Underwriting Agreement (Kosmos Energy Ltd.), Underwriting Agreement (Kosmos Energy Ltd.), Underwriting Agreement (Kosmos Energy Ltd.)

PFIC Status. Based on the past and projected composition of its income and assets, and the valuation of its assets, including goodwill, the Company does not currently expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable futureyear.

Appears in 2 contracts

Sources: Underwriting Agreement (Reitar Logtech Holdings LTD), Underwriting Agreement (Reitar Logtech Holdings LTD)

PFIC Status. Based on the past Company’s current and projected composition expected income and assets and the market value of its income and assets, and the valuation of its assets, including goodwillAmerican Depositary Shares, the Company does not expect to be a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 2 contracts

Sources: Underwriting Agreement (iClick Interactive Asia Group LTD), Underwriting Agreement (iClick Interactive Asia Group LTD)

PFIC Status. Based on the past Company’s current income and projected composition assets and projections as to the value of its income and assets, assets and the market value of its ADSs, including the current and anticipated valuation of its assets, including goodwill, the Company does not expect to be a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 2 contracts

Sources: Underwriting Agreement (Molecular Data Inc.), Underwriting Agreement (Bilibili Inc.)

PFIC Status. Based on the past Company’s current projected income, assets and projected composition of its income and assets, and the valuation of its assets, including goodwillactivities, the Company does not expect to be a treated as “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its the current taxable year or in the foreseeable futurefor any future taxable year.

Appears in 2 contracts

Sources: Underwriting Agreement (Nord Anglia Education, Inc.), Underwriting Agreement (Nord Anglia Education, Inc.)

PFIC Status. Based on the past Company’s current income and projected composition assets and projections as to the value of its income and assets, assets and the market value of its American Depositary Shares, including the current and anticipated valuation of its assets, including goodwill, the Company does not expect to be a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 2 contracts

Sources: Underwriting Agreement (Baozun Inc.), Underwriting Agreement (Baozun Inc.)

PFIC Status. Based on the past Company’s current income and projected composition income, the current value of its income assets and assets, projections as to the value of its assets and the valuation market value of its assets, including goodwillADSs, the Company does not expect to be a passive foreign investment company” (“PFIC”) , as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (RISE Education Cayman LTD)

PFIC Status. Based on the past Company’s current projected income, assets and projected composition of its income and assets, and the valuation of its assets, including goodwillactivities, the Company does not expect to be classified as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current the taxable year or in ending December 31, 2010 and the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (Global Education & Technology Group LTD)

PFIC Status. Based on the past and projected current expected composition of its the Company’s income and assets, assets and the valuation value of its assets, including goodwill, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its current taxable year or in the foreseeable futureyear.

Appears in 1 contract

Sources: Underwriting Agreement (Genetron Holdings LTD)

PFIC Status. [Based on the past and projected composition of its the Company’s income and assets, and the valuation of its assets, including goodwill, the Company does not expect to be believe that it was a passive foreign investment company” company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its most recent taxable year and does not expect to become a PFIC in the current taxable year or in the foreseeable future.]

Appears in 1 contract

Sources: Underwriting Agreement (Yalla Group LTD)

PFIC Status. Based on the past and projected composition of its income and assets, and the valuation of its assets, including goodwill, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.;

Appears in 1 contract

Sources: Underwriting Agreement (Full Truck Alliance Co. Ltd.)

PFIC Status. Based on the past upon its current and projected composition of its income and assets, including the proceeds from this offering and projections as to the valuation value of its assets, including goodwilland subject to the qualifications set forth in the Registration Statements and the Prospectus, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), for its current taxable year or in the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (MOGU Inc.)

PFIC Status. Based on the past and projected composition of its the Company’s income and assets, and the valuation of its assets, including goodwill, the Company does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (Tudou Holdings LTD)

PFIC Status. Based on its current operations, income, assets and certain estimates and projections, including as to the past and projected composition of its income and assets, and the valuation relative values of its assets, including goodwill, the Company does believes it will not expect to be a “passive foreign investment company” Passive Foreign Investment Company (“PFIC”) as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or ending December 31, 2018, and does not expect to become a PFIC in the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (Hudson Ltd.)

PFIC Status. Based on the past Company’s current income and projected composition asset and projections as to the value of its income assets and assets, and the valuation market value of its assets, including goodwillADSs, the Company believes that it was not and does not expect to be a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, amended for its the current taxable year or in the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (Uxin LTD)

PFIC Status. Based on the past Company’s financial statements and the projected composition of its income and assets, and the valuation of its assets, including goodwill, the Company does not expect to be classified as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year or in the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (500.com LTD)

PFIC Status. Based on the past Company’s current and projected composition of its income income, assets and assets, and the valuation of its assets, including goodwillactivities, the Company does not expect to be classified as a “passive foreign investment company” (“PFIC”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for its current taxable year ending December 31, 2011 or in the foreseeable future.

Appears in 1 contract

Sources: Underwriting Agreement (Taomee Holdings LTD)