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6/17/99 TS (co-counsel with writer) advises that none of B’s shareholders are U.S. persons and, thus, their respective minority takings of A’s stock would be exempt under 802.51(b). As to...

6/16/99 - Discussed with co-counsel and letter writer. As to Trans. One, if X and Y are competitors, presumption raised against use of 802.9. X’s entering into similar agreements with other cos. not...