PFIC definition

PFIC means a passive foreign investment company as defined in the Code.

PFIC means a passive foreign investment company.

PFIC means a “passive foreign investment company” within the meaning of Section 1297 of the Code;

Examples of PFIC in a sentence

• Please see “Material U.S. Federal Income Tax Consequences — U.S. Holders — U.S. Federal Income Tax Consequences of the Domestication to U.S. Holders of Brilliant Securities — Passive Foreign Investment Company Status” for a more detailed discussion with respect to Brilliant’s potential PFIC status and certain tax implications thereof.

• There is no assurance that Brilliant is not currently or has not been a PFIC during a U.S. Holder’s holding period.

• P2(MA), P(MB), MC = P2(FRA), P(FRB), FRC − i P2(FIA), P(FIB), FI C + i P2(FRA), P(FRB), FI C + i P2(FRB), P(FRC), FI A + i P2(FRC), P(FRA), FIB − P2(FIA), P(FIB), FRC − P2(FIB), P(FIC), FRA − P2(FI C), P(FIA), FRB (60)2Like before, this is a linear combination of the cubic forms phase-shifted every π [rad].

• In addition, U.S. Holders of Brilliant Ordinary Shares, Brilliant Rights and Brilliant Warrants may be subject to adverse U.S. federal income tax consequences under the PFIC.

• If Brilliant is a PFIC or has been a PFIC during a U.S. Holder’s holding period, such U.S. Holder may be subject to certain adverse U.S. federal income tax consequences as a result of the Domestication.

More Definitions of PFIC

PFIC means a passive foreign investment company for U.S. federal income tax purposes;

PFIC has the meaning set forth in ‎Section 5.7;

PFIC means a passive foreign investment company within the meaning of Section 1297 of the Code;

PFIC shall have the meaning assigned to such term in Section 3.1(kk).

PFIC shall have the meaning ascribed to such term in Section 4.18.

PFIC means a Passive Foreign Investment Company within the meaning of Section 1297(a) of the United States Internal Revenue Code of 1986, as amended.

PFIC has the meaning set forth in Section 8.01(j).