Common use of PFIC Status Clause in Contracts

PFIC Status. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Time of Sale Disclosure Package and the Prospectus, the Company believes that it will not be a passive foreign investment company (a “PFIC”), as defined in section 1297 of the Internal Revenue Code of 1986, as amended, in its current taxable year and does not anticipate becoming a PFIC in future years.

PFIC Status. Subject to the qualifications, limitations, exceptions and assumptions qualifications set forth in the Registration Statement, the Time of Sale Disclosure Package and the Prospectus, the Company believes that it will does not expect to be a passive foreign investment company (a “PFIC”), as defined in section 1297 of the Internal Revenue Code of 1986, as amended, in for its current taxable year and does not anticipate becoming a PFIC or in future years.the foreseeable future; EXECUTION VERSION

PFIC Status. Subject to the qualifications, limitations, exceptions and assumptions set forth in the Registration Statement, the Time of Sale Disclosure Package Statement and the Prospectus, the Company believes does not believe that it will not be was a “passive foreign investment company company” (a “PFIC”), ) as defined in section Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (the “Code”), in its current for the taxable year ended December 31, 2012, and does not anticipate becoming being a PFIC in future yearsfor its current or any subsequent taxable year.

PFIC Status. Subject to the qualifications, limitations, exceptions and assumptions qualifications set forth in the Registration Statement, the Time of Sale Disclosure Package and the Prospectus, the Company believes that it will does not expect to be a passive foreign investment company (a “PFIC”), as defined in section 1297 of the Internal Revenue Code of 1986, as amended, in for its current taxable year and does not anticipate becoming a PFIC or in future years.the foreseeable future;

PFIC Status. Subject to the qualifications, limitations, exceptions and assumptions set forth in in, and except as otherwise disclosed in, the Registration Statement, the Time of Sale Disclosure Package Statement and the Prospectus, the Company believes does not believe that it will not be was a passive foreign investment company (a “PFIC”)company, as defined in section 1297 of the Internal Revenue Code of 1986, as amended, in for its current taxable year and does not anticipate becoming a PFIC in future yearsending December 31, 2021.