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11/20/96 A should report for its acquisition of B assets. Subsequent formation of LLC is exempt. To meet “continuum theory” criteria, the last event must be reportable which it is not here. RS concurs...

11/14/96 Advised writer that it was the view of the PMN Office (PS, NO, TH and VC) that(redacted) can qualify as a finance company under 802.64(a)(7). I pointed out to the writer that in order to use...

11/14/96 - Agreed with conclusion of letter. In order to have an objective, easily administrable control by contract criterion, the test is whether the person has the contractual power to appoint half...

11/8/96 – Advised caller’s assistant that income from securities and other investments must be included in revenues for 802.51(d) even though such securities and investments may be in foreign firms...