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determine total US assets of all of the foreign issuers. Determine total US sales of all foreign issuers and foreign assets (aggregated under 801.15(d)). If both of these do not exceed $50 million (as...

Proper analysis: 1. Under 802.51 /802.50 - determine total US assets of all of the foreign issuers. Determine total US sales of all foreign issuers and foreign assets (aggregated under 801.15(d)). If...

but you might possibly be exempt under 802.51(c) if the combined US sales and US assets of both parties do not exceed $150.1 million.

but you might possibly be exempt under 802.51(c) if the combined US sales and US assets of both parties do not exceed $150.1 million.

but you might possibly be exempt under 802.51(c) if the combined US sales and US assets of both parties do not exceed $150.1 million.

1. We have historically treated S.a.r.L. entities as non-corporate. 2. We are fine with these multiple steps all being treated as part of the JV formation K Walsh concurs. UPDATE June 1, 2016...

Agree. K Walsh concurs.