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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...

Based upon the agreement of the parties to consummate the transaction requiring C to convert debt into equity as an integral step in the acquisition process and because C will only hold the voting...

Section 801.40 applies to this transaction based on the fact including: identity of the purchasers is known, sale of stock is timely to the shareholders and IPO; the money raised is used to purchase...

Acquisition of credit card servicing rights relating to the authorization, clearing & settlement of transactions based on credit card sales is considered an acquisition of assets that is exempt as...