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  4. Should the intercompany charges to foreign affiliates for the reimbursement of management time and expense, advertising expense, etc. be considered "sales" for the purpose of the survey?

Should the intercompany charges to foreign affiliates for the reimbursement of management time and expense, advertising expense, etc. be considered "sales" for the purpose of the survey?

Yes. These would be considered "sales" for purposes of this survey as long as the charges are from the U.S. operations to foreign affiliates. Intercompany charges from your foreign affiliates to other foreign entities are not covered on this survey.

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