Case No. IA-10466

Date issued: Aug. 27 2008

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TURBOFAC Commentary (1542 words)

Key Takeaway - 560.505 May Cover Certain Deemed Exports of CCL-Listed Technology Licensed by BIS

Consolidated Comment on Case No. IA-10466 and Case No. IA-11787

1) BACKGROUND

Case No. IA-10466 and Case No. IA-11787 (both in native PDF file) are virtually identical guidance letters issued to the same company four and a half years apart. The primary distinctions between the two letters are (i) that the first one address the ITR, while the second one addressed the reissued ITSR, (ii) the second letter redacts the name of the Iranian national employee, who is likely different from the person at issue in the first letter...