1108001 Informal Interpretation

Date:
Rule:
Item 5
Staff:
Kathryn Walsh
Response/Comments:

  – Yes. KB agrees.

Question

From:(Redacted)
Sent: Thursday, August 11, 2011 6:36AM
To: Walsh,Kathryn
Cc: Berg, Karen E.
Subject: Re: item 5 revenues

Undernew Item 5, if a foreign manufacturer sells product to an independent foreigntrading company which resells to US customers, my view is that such sales donot get reported in Item 5 because the US customers are not customers of thefiling party and the foreign manufacturer has no control over the sales of thetrading company even though it knows that the trading company resells to UScustomers.

Doyou agree?

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