definiens: ( ) as defined in the U.S. Internal Revenue Code of 1986, as amended ( or any successor thereto ) ( the ) and ( ii ) to determine whether each of the Mutual Fund Investors or their respective Affiliates is required to report its pro rata portion of the Corporation ’s Subpart F Income on its United States federal income tax return, or to allow each of the Mutual Fund Investor s or their respective Affiliates to otherwise comply with applicable United States federal income tax laws . The Corporation and the Existing Shareholders shall not, without the written consent of each of the Mutual Fund Investors issue or transfer stock in the Corporation to any investor if, following such issuance or transfer the Corporation, in the determination of counsel or accountants for any of the Mutual Fund Investors, ( such opinion also to be addressed to the Corporation ), would be a CFC . For the p urposes of this Section 7.3, the term, with respect to any Mutual Fund Investor, shall include but not be limited to any person that receives, whether directly or indirectly, investment management or investment advisory services from such Mutu al Fund Investor, or any of such party ’s respective Affiliates