Question
From: (Redacted)
Sent: Tuesday, February 15, 2011 7:34 PM
To: Verne, B. Michael
Cc: (Redacted)
Subject: RE: Item 5 questions
Mike:
Good evening. Another Item 5 questionfor your consideration:
Company A has offshore drilling/extractionoperations near continental U.S. Some of Company A's operations are in the formof non-controlled JVs (see (2) in my email below). Would the treatment ofCompany A's revenues derived from those operations depend on whether theoperations are in U.S. territorial waters (something along the lines of this http://en.wikipedia.org/wiki/Teritorial_waters)? So that:
3. Regardlessof whether the drilling/extraction operations occur in U.S. waters, if the product is then taken onshore, safes of the product onshore should beincluded in Item 5.
Thank you very much in advance.
From: (Redacted)
Sent: Friday, July 09, 2010 10:51 PM
To: Verne, B. Michael
Cc: (Redacted)
Subject: RE: Item 5 questions
Mike,
Sorry -just a couple more questions:
1. In hypothetical (3) below, the revenues from thesales of products by the foreign entity to the U.S. entity within the samegroup (which the U.S. entity then resells on its own account) do not need to beincluded.
2. The client has contractual JVs in the U.S., some of which it does not control or operate. The client owns and sells its equity percentageof product. These revenues would need to be reported regardless of the locationof customer because they are derived by the client's U.S. based entities andare of products that originate in the U.S.
Please let me know if you agree.