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Parent A's side of the formation is exempt. For purposes of 802.50, Company A's sales for services provided in the US should be attributed to the US assets. The cost of sales cannot be excluded.

Whether a satellite is considered to be located in or outside the United States turns on whether its owner qualifies as a ‘foreign person’ under Section 801.1(e)(2)(i). If its owner qualifies as a...

The acquisition of the 50% interest in the JV is exempt under 802.51. 802.4 may apply if the 50% interest in the JV was not being distributed.