Agree.
Question
From: Shaffer, Kristin
Sent: Wednesday, February 28, 2018 10:58:27 AM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: [Redacted]
Subject: RE: Question on meaning of foreign assets for purposes of §802.51
[Redacted]
We agree.
Best regards,
Kristin
----------------------
From: [Redacted]
Sent: Tuesday, February 27, 2018 5:25:26 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: [Redacted]
Subject: Question on meaning of foreign assets for purposes of §802.51
Hi all,
We have a question for you on the application of 16 C.F.R. §802.51. We are representing a company seeking to acquire a bank (“Target”) which is incorporated and headquartered outside the U.S. In its most recent fiscal year, Target made aggregate sales in/into the U.S. under the forthcoming $84.4m threshold.
Please could you confirm that the following categories of assets, which are held by Target, would be viewed as assets located outside the U.S. for purposes of §802.51:
1. A non-U.S. dollar-denominated loan booked by a non-U.S. subsidiary or branch office of a non-U.S. issuer to customers located in the U.S.; and
2. A non-U.S. dollar-denominated loan booked by a non-U.S. subsidiary or branch office of a non-U.S. issuer to a non-U.S. subsidiary of a U.S. customer.
Please let me know if you have questions and thanks in advance for your assistance.
[Redacted]