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Confirmed that it is proper to view this transaction as an acquisition by A of the assetsof B, since A will control the Board of Newco at the time of acquisition with the powerto appoint 13 of 18 of...

4/1/96 - Called letter writer and advised that procedure set forth in this letter was correct under 801.11 to determine size of acquiring person. As set forth in ABA letter#169, acquiring person can...

3/29/96 - Called writer and advised that transfers of assets by A and B to C, a financialinstitution, with a lease financing arrangement then being entered into between A and C(but not B) still could...

3/29/96- Advised writer that asset is a foreign asset. Of course, if sale is to a U.S.person (802.50), then $25MM of sales into the U.S. could make purchase reportablewhether a voting stock or asset...