Common use of Passive Foreign Investment Company Clause in Contracts

Passive Foreign Investment Company. The Company was not a passive foreign investment company (“PFIC,” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Based on the projected composition of its income and valuation of its assets, including goodwill, the Company was does not expect to be a 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 the “Code”) for its most recent taxable yearyear ending on December 31, 2011 and the Company does not expect to be become a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its the current taxable year or in the foreseeable futuretax year.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2010, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2007, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company believes it was not a passive foreign investment company (“PFIC,” ”) as defined in under Section 1297 of the United States Internal Revenue Code of 1986for the taxable year ended December 31, as amended, the “Code”) for its most recent taxable year2020, and the Company does not expect to be a PFIC for its in the current taxable year ending December 31, 2021, or in the foreseeable future.

Passive Foreign Investment Company. The Company was will not 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, amended (the “Code”) ), for its most recent the taxable yearyear ending December 31, 2013, and based on the Company’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Company does not expect believe that it is likely to be become a PFIC for its current taxable year or in the foreseeable futureany future tax year.

Passive Foreign Investment Company. The As of the date hereof, the Company was believes, after due inquiry, and based on its current operations and expected financial results, that it will not constitute a “passive foreign investment company (“PFICcompany,” as such term is defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, amended (the “Code”) for its most recent taxable year), and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable futureending December 31, 2013.

Passive Foreign Investment Company. The Company was does not believe that it will be a 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, the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC regulations and published interpretations thereunder for its current taxable year or ending December 31, 2013 and does not expect to become one in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2009, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Based on the composition of its income and assets, the Company believes, after due inquiry, that it was not a “passive foreign investment company (“PFIC”),” as such term is defined in Section 1297 of the United States U.S. Internal Revenue Code of 1986, as amended, amended (the “Code”) ), for its most recent taxable yearyear ending February 28, 2013 and, based on the projected composition of its income and assets, the Company does not expect to that it will be a PFIC for its the current taxable year or in the foreseeable futureending February 28, 2014.

Passive Foreign Investment Company. The Company does not believe it was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) amended for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (a “PFIC”), the “Code”) for its most recent taxable yearyear ended December 31, 2009, and the Company it does not expect to be a PFIC for its current future taxable year or in years during the foreseeable future.term of the Securities;

Passive Foreign Investment Company. The Company was does not expect to be a 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 the “Code”) for its most recent taxable yeartax year ending December 31, and the 2007. The Company does not expect has no plan or intention to be operate in such a manner so as to become a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was believes that it will not be considered for the current year or in the foreseeable future a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 1296 of the United States U.S. Internal Revenue Code of 1986, as amended, amended (the “Code”) for its most recent taxable year, and or a “foreign personal holding company” within the Company does not expect to be a PFIC for its current taxable year or in meaning of Section 552 of the foreseeable futureCode.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (a “PFIC”), the “Code”) for its most recent taxable yearyear ended December 31, 2011, and the Company it does not expect to be a PFIC for its current future taxable year or in years during the foreseeable future.term of the Securities;

Passive Foreign Investment Company. The Company was is not a “passive foreign investment company” within the meaning of Section 1297 of the U.S. Internal Revenue Code of 1986 (the “Code”), as amended, for the 2005 taxable year and the Company does not anticipate becoming a passive foreign investment company (“PFIC,” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent any future taxable year, and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable year, and the regulations and published interpretations thereunder for the taxable year ending March 31, 2010 and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was is not currently a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1296 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable year1966, and the Company does is not expect likely to be become a PFIC for its current taxable the year or in the foreseeable futureending December 31, 2013.

Passive Foreign Investment Company. The Company was does not believe it should be treated as a “passive foreign investment company company” (“PFIC,” ”), as defined in Section 1297 of the United States Internal Revenue Code of 1986Code, as amended, the “Code”) for its most recent recently completed taxable year, and based on its current operations, income, assets and certain estimates and projections, including as to the relative value of its assets, the Company does not expect to be a PFIC for its current taxable year or to become one in the foreseeable future.

Passive Foreign Investment Company. The Based on the projected composition of its income and valuation of its assets, including goodwill, the Company was does not expect to be a 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 the “Code”) for its most recent taxable yearyear ending on December 31, 2012 and the Company does not expect to be become a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not 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, the “Code”) amended for its most recent recently completed 2021 taxable yearyear and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, for the “Code”) for its most recent taxable yeartax year ending December 31, and the 2011. The Company does not expect has no plan or intention to be operate in such a manner so as to become a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending September 30, 2010, and the Company does not expect to be become a PFIC for its current taxable year or in the foreseeable future, although there can be no assurance in this regard.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (a “PFIC”), the “Code”) for its most recent taxable yearyear ended December 31, 2006, and the Company it does not expect to be a PFIC for its current future taxable year or in years during the foreseeable futureterm of the Securities.

Passive Foreign Investment Company. The Company was not a passive foreign investment company (“PFIC,”) or a “controlled foreign corporation” as such terms are defined in Section under section 1297 of the United States U.S. Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable yearyear ended September 30, 2005 and, based on the Company’s current and projected income, assets and activities, the Company does not expect to be classified as a PFIC for its current any subsequent taxable year or in the foreseeable futureyear.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2019 and future taxable years, and the Company does not expect has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was not a passive foreign investment company (“PFIC,” ”) as defined in under Section 1297 of the United States Internal Revenue Code of 1986for the taxable year ended December 31, as amended, the “Code”) for its most recent taxable year2015, and the Company does not expect to be a PFIC for its in the current taxable year ending December 31, 2016, or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (a “PFIC”), the “Code”) for its most recent taxable yearyear ended December 31, 2012, and the Company it does not expect to be a PFIC for its current future taxable year or in years during the foreseeable future.term of the Securities;

Passive Foreign Investment Company. The Company was does not expect to be a 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, and the “Code”regulations and published interpretations thereunder for the taxable year (i) for its most recent taxable yearended March 31, 2006, and (ii) ending March 31, 2007, and has no current plan or intention to conduct its business in a manner that would reasonably be expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Based on the estimated composition of its income, assets and operations for 2020, the Company believes that it was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, for the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable futureending December 31, 2020.

Passive Foreign Investment Company. The Company believes that it was not a “passive foreign investment company (“PFIC,company” as defined in within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, and the “Code”) for its most recent regulations promulgated thereunder, in the Company’s previous taxable year, and the Company does anticipates that it will not expect to be a PFIC for its passive foreign investment company in the Company’s current taxable year or in any taxable year in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for U.S. federal income tax purposes in 2020, based on its most recent taxable yearincome, assets and business activities, and the Company it does not expect to be a PFIC for its current taxable year or in the foreseeable near future.

Passive Foreign Investment Company. The Company was does not believe it currently is or has been 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, the “Code”) for its most recent taxable year, and the Company does not expect to be become a PFIC for its current taxable year or in the foreseeable future.; and

Passive Foreign Investment Company. The Company was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (a “PFIC”), the “Code”) for its most recent taxable yearyear ended December 31, 2008, and the Company it does not expect to be a PFIC for its current future taxable year or in years during the foreseeable futureterm of the Securities.

Passive Foreign Investment Company. The Company was believes that it will not 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, the “Code”) for its most recent current taxable yearyear and, based on the Company’s current operations and the Company future projections, it does not expect to be classified as a PFIC for its current any subsequent taxable year or in the foreseeable futureyear.

Passive Foreign Investment Company. The Company was will not 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, amended (the “Code”) ), for its most recent the taxable yearyear ending December 31, 2012, and based on the Company’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Company does not expect believe that it is likely to be become a PFIC for its current taxable year or in the foreseeable futureany future tax year.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, amended and the regulations and published interpretations thereunder (the “Code”) ), for its most recent the taxable yearyear ending December 31, 2008, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2014, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company (“PFIC,” as defined in ”) within the meaning of Section 1297 of the United States U.S. Internal Revenue Code of 1986, as amended, the “Code”) for its most recent current taxable year, and the Company does not expect to be become a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company does not believe that it was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States U.S. Internal Revenue Code of 1986, as amended, amended (the “Code”) ), for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2013, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending March 31, 2011, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was not a passive foreign investment company (“PFIC,” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company believes that it was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) 1986 for its most recent recently completed taxable year, and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2011, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable yearyear and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for its current the subsequent taxable year or in the foreseeable futureyear.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC regulations and published interpretations thereunder for its current taxable year ending December 31, 2011 or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a passive foreign investment company “Passive Foreign Investment Company” (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amendedamended for the taxable year ended December 31, 2015 and, based on the “Code”) for its most recent taxable yearCompany’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for its the current taxable year ending December 31, 2016. The Company has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the foreseeable futureCompany becoming a PFIC in the future under current laws and regulations.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent taxable yearthe year ending December 31, 2013, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company does not believe it was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company it does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a passive foreign investment company (“PFIC,” ”) as defined in under Section 1297 of the United States Internal Revenue Code of 1986for the taxable year ended December 31, as amended, the “Code”) for its most recent taxable year2013, and the Company does not expect to be a PFIC for its in the current taxable year ending December 31, 2014, or in the foreseeable future.

Passive Foreign Investment Company. The Based on the composition of its income and assets, the Company believes, after due inquiry, that it was not a “passive foreign investment company (“PFIC”),” as such term is defined in Section 1297 of the United States U.S. Internal Revenue Code of 1986, as amended, amended (the “Code”) ), for its most recent taxable yearyear ending February 29, 2012 and, based on the projected composition of its income and assets, the Company does not expect to that it will be a PFIC for its the current taxable year or in the foreseeable futureending February 28, 2013.

Passive Foreign Investment Company. The Company believes that it was not a 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, the “Code”) for its most recent recently completed taxable year, year and the Company it does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending December 31, 2006, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Title 26 U.S. Code Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC regulations and published interpretations thereunder for its current the taxable year ending December 31, 2007 or in the foreseeable futurefuture although no assurance can be given in this regard.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (a “PFIC”), the “Code”) for its most recent taxable yearyear ended December 31, 2013, and the Company it does not expect to be a PFIC for its current future taxable year or in years during the foreseeable future.term of the Securities;

Passive Foreign Investment Company. The Company was not 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, the “Code”) amended for its most recent 2021 taxable yearyear and, based on the Company’s current projected income, assets and activities, the Company does not expect to be classified as a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was does not believe that it will be a 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, the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC regulations and published interpretations thereunder for its current taxable year or ending December 31, 2012 and does not expect to become one in the foreseeable future.

Passive Foreign Investment Company. The Company believes that it was not a passive foreign investment company (a “PFIC,” as defined in ”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for with respect to its most recent 2019 taxable year, and the Company does not expect to be anticipate becoming a PFIC for its current 2020 taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not 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, the “Code”) for its most recent taxable year, year and the Company does not expect to be a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was should not 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, amended (the “Code”) ), for its most recent the taxable yearyear ending December 31, 2013, and based on the Company’s current and expected assets, income and operations as described in the Registration Statement, the Time of Sale Prospectus and the Prospectus, the Company does not expect believe that it is likely to be become a PFIC for its current taxable year or in the foreseeable futureany future tax year.

Passive Foreign Investment Company. The Company was not 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, the “Code”) for its most recent taxable year, and the Company does believes that it will not expect to be a PFIC for its current taxable year or in and, based on the foreseeable futureCompany's current operations and future projections, it does not expect to be classified as a PFIC for any subsequent taxable year.

Passive Foreign Investment Company. The Company was does not expect to be a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, and the “Code”) regulations and published interpretations thereunder for its most recent the taxable yearyear ending May 31, 2007, and has no plan or intention to conduct its business in a manner that would be reasonably expected to result in the Company does not expect to be becoming a PFIC for its current taxable year or in the foreseeable futurefuture under current laws and regulations.

Passive Foreign Investment Company. The Company was does not expect to be a 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 the “Code”) for its most recent taxable yeartax year ending December 31, and the 2006. The Company does not expect has no plan or intention to be operate in such a manner so as to become a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was is not a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 of the United States U.S. Internal Revenue Code of 1986, as amended, the “Code”) for its most recent taxable year, and the Company does not expect to be become a PFIC for its current taxable year or in the foreseeable futureending December 31, 2005.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company company” (“PFIC,” ”) as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company does not expect to be a PFIC for its the current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company does not believe that it was not a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1297(a) of the United States Internal Revenue Code of 1986, as amended, for the “Code”) for its most recent taxable yearyear ended June 30, and the Company 2014, does not expect to be a PFIC for its in the current taxable year or in the foreseeable futureending June 30, 2015.

Passive Foreign Investment Company. The Company was believes that it is not a passive foreign investment company Passive Foreign Investment Company (“PFIC,” as defined in ”) within the meaning of Section 1297 1296 of the United States Internal Revenue Code of 1986, as amended, the “Code”) for its most recent recently completed taxable year, year and the Company does expects to operate so as not expect to be become a PFIC for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was 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, the “Code”) for its most recent taxable year, and the Company does not expect to be a PFIC amended for its current taxable year or in the foreseeable future.

Passive Foreign Investment Company. The Company was not a “passive foreign investment company (“PFIC,company” as defined in Section 1297 of the United States Internal Revenue Code of 1986, as amendedamended (a “PFIC”), the “Code”) for its most recent taxable yearyear ended December 31, 2014, and the Company it does not expect to be a PFIC for its current future taxable year or in years during the foreseeable future.term of the Securities;