PFIC. The Company does not believe it was a passive foreign investment company (“PFIC”) within the meaning of Section 1297(a) of the Code for the year ended December 31, 2021 and, based on the Company’s current projected income, assets and activities and after giving effect to the offering and sale of the Firm Shares and the application of the proceeds thereof as described in the Registration Statement and the Prospectus, the Company does not expect to be a PFIC in the current or any subsequent taxable year.
Appears in 2 contracts
Samples: Underwriting Agreement (T20 Holdings Ltd.), Underwriting Agreement (T20 Holdings Ltd.)
PFIC. The Company does not believe it was a passive foreign investment company (“PFIC”) within the meaning of Section 1297(a) of the Code for the year years ended December 31, 2021 2019 and 2020 and, based on the Company’s current projected income, assets and activities and after giving effect to the offering and sale of the Firm Shares Securities and the application of the proceeds thereof as described in the Registration Statement Statement, the Pricing Disclosure Package and the Prospectus, the Company does not expect to be a PFIC in the current or any subsequent taxable year.
Appears in 2 contracts
Samples: Underwriting Agreement (Versus Systems Inc.), Underwriting Agreement (Versus Systems Inc.)
PFIC. The Company does not believe it was a passive foreign investment company (“PFIC”) within the meaning of Section 1297(a) of the Code for the year ended December 31, 2021 2019 and, based on the Company’s current projected income, assets and activities and after giving effect to the offering and sale of the Firm Shares Securities and the application of the proceeds thereof as described in the Registration Statement Statement, the Pricing Disclosure Package and the Prospectus, the Company does not expect to be a PFIC in the current or any subsequent taxable year.
Appears in 2 contracts
Samples: Underwriting Agreement (Versus Systems Inc.), Underwriting Agreement (Versus Systems Inc.)
PFIC. The Company does not believe it was a passive foreign investment company (“PFIC”) within the meaning of Section 1297(a) of the Code for the year ended December 31, 2021 and, based on the Company’s current projected income, assets and activities and after giving effect to the offering and sale of the Firm Shares Securities and the application of the proceeds thereof as described in the Registration Statement and the Prospectus, the Company does not expect to be a PFIC in the current or any subsequent taxable year.
Appears in 1 contract
