Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 2012, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
Appears in 3 contracts
Samples: Underwriting Agreement (Golar LNG Partners LP), Underwriting Agreement (Golar LNG Partners LP), Underwriting Agreement (Golar LNG Partners LP)
Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122017, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
Appears in 2 contracts
Samples: Underwriting Agreement (Golar LNG Partners LP), Underwriting Agreement (Golar LNG Partners LP)
Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122013, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
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Passive Foreign Investment Company. The Based on its current and projected method of operations, and an opinion of its U.S. counsel, the Partnership will should not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122016, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe reasonably expects that it is likely to become will not be treated as a PFIC for any future taxable tax year.
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Passive Foreign Investment Company. The Based on its current and projected method of operations, and an opinion of its U.S. counsel, the Partnership will should not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122014, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe reasonably expects that it is likely to become will not be treated as a PFIC for any future taxable tax year.
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Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), ) for the taxable year ending December 31, 20122011, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
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Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122017, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package Registration Statement and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
Appears in 1 contract
Samples: Equity Distribution Agreement (Golar LNG Partners LP)
Passive Foreign Investment Company. The Based on its current and projected method of operations, and an opinion of its U.S. counsel, the Partnership will should not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for the taxable year ending December 31, 20122018, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe reasonably expects that it is likely to become will not be treated as a PFIC for any future taxable tax year.
Appears in 1 contract
Samples: Hoegh LNG Partners LP
Passive Foreign Investment Company. The Based on its current and projected method of operations, and an opinion of its U.S. counsel, the Partnership will should not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”)amended, for the taxable year ending December 31, 20122017, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe reasonably expects that it is likely to become will not be treated as a PFIC for any future taxable tax year.
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Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), ) for the taxable year ending December 31, 20122016, and based on the Partnership’s current and expected assets, income and operations as described in the Registration Statement, the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
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Samples: VTTI Energy Partners LP
Passive Foreign Investment Company. The Partnership will was not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending ended December 31, 20122016, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to be a PFIC for its current tax year or to become a PFIC for any future taxable tax year.
Appears in 1 contract
Samples: KNOT Offshore Partners LP
Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122016, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable tax year.
Appears in 1 contract
Samples: KNOT Offshore Partners LP
Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122013, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable tax year.
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Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122014, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable tax year.
Appears in 1 contract
Samples: KNOT Offshore Partners LP
Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), ) for the taxable year ending December 31, 20122014, and based on the Partnership’s current and expected assets, income and operations as described in the Registration Statement, the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
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Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122015, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable tax year.
Appears in 1 contract
Samples: KNOT Offshore Partners LP
Passive Foreign Investment Company. The Partnership will not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122015, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe that it is likely to become a PFIC for any future taxable year.
Appears in 1 contract
Passive Foreign Investment Company. The Based on its current and projected method of operations, and an opinion of its U.S. counsel, the Partnership will should not be a Passive Foreign Investment Company (“PFIC”) within the meaning of Section 1297 of the United States Internal Revenue Code of 1986, as amended (the “Code”), for the taxable year ending December 31, 20122017, and based on the Partnership’s current and expected assets, income and operations as described in the Disclosure Package and the Prospectus, the Partnership does not believe reasonably expects that it is likely to become will not be treated as a PFIC for any future taxable tax year.
Appears in 1 contract