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Date
Rule
802.51
Staff
Nancy Ovuka
Response/Comments
Yes, products manufactured in the US would constitute sales in or into the US, regardless of their final destination.

Question

From: [redacted]

To: novuka@ftc.gov

Date: 3/14/02

Re: foreign person exemption

Nancy,

In an acquisition of 100% of the voting securities of a foreign issuer, the foreign issuer has a wholly-owned US subsidiary that sells its manufactured products to vendees inside and outside of the US. Are the revenues from sales to vendees outside the US counted as "sales in or into the US" for purposes of the foreign person exemption?

Thank you.

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