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An irrevocable proxy to vote shares does not, by itself constitute beneficial ownership of the shares & thus, the holder of the proxy does not hold these shares even though they must be aggregated...

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See below 3/30/94 The Company has named itself and some of its subsidiaries as the beneficiaries of the Trustestablished by the Company, i.e., the settlor. The Commission, on pg. 33459 of the 7/31...

See below 3/29/84 - advised writer that under the PMN Offices treatment of accounts receivable, this transaction is non-reportable under 7A(c)(1) and 802.1(b) as a transfer in the ordinary course of...

See below 3/21/94 Advised writer that my views reflected only those of the PMN Office and were not those of the FTC and did not bind it. Writer said that CA had recently passed a partnership merger...

See below I concur with this letter. We are not giving advice on the Robinson Patman Act or other antitrust laws. The PMN Office gives advice on the H-S-R Act. As long as the v/s of T are valued in...

See below 3/11/94 Advised writer that a REITs purchase of the assets or voting stock of another REIT is exempt under 7A(c)(1). However, the acquisition of the voting stock of a REIT by someone other...

See below 3/3/94 Advised writer that transactions described in this letter would result in no reportable events. R.B. Smith

See below 3/1/94 Called writer and advised that no filing need be made for the acquisition of Company C since it is not engaged in manufacturing, has sales less than $100 MM and its last regularly...

See below 3/1/94 Advised writer that if grantor names itself as beneficiary of trust (and paragraph 3(b) seems to clearly establish such), then SBP of 7/31/78 at 33459 states that the settlor is...

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See below This escrow arrangement is OK. RS concurs.

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See below 2/28/94 Advised writer that no filing is required. Exempt under interpretations the PNM Office has given regarding re-incorporations under 802.10 or the fact that the acquiring persons...

2/18/94 - advised author of letter that, based on the facts presented, no filing need be made for the sale and purchase of the (redacted). RBSmith