Romulo, Mabanta, Buenaventura
SEC Opinion • Securities and Exchange Commission • Opinions • Aug 8, 1996
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August 8, 1996 Romulo, Mabanta, Buenaventura Sayoc & De Los Angeles 30th Flr., Citibank Tower 8741 Paseo de Roxas Makati City Attention : Attys . Perry L . Pe and Luis G . De Dios S i r : This refers to your letter dated July 29, 1996 requesting opinion on whether " leasehold or usufructuary rights " can be used as consideration or payment of shares of stock. Please be advised that the Commission, in its meeting of September 16, 1993, had previously considered valuation of leasehold right as part of the payment to the increase of the authorized capital stock of Kephil Shipyard, Inc. In view thereof, the Commission will not interpose any objection to the proposal in your letter to use leasehold or usufructuary rights as payment for issuance of shares of stocks, provided that a comprehensive appraisal report is submitted to support the valuation thereof subject to the usual examination of the valuation to be conducted by this Commission. Very truly yours, (SGD.) FE ELOISA C. GLORIA Associate Commissioner
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