ASAT, Inc. - Page 4

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                                  FINDINGS OF FACT                                    
               Petitioner, ASAT, Inc., is a corporation organized under the           
          laws of California.  At the time the petition was filed, its                
          principal place of business was in Palo Alto, California.                   
          Petitioner's Organizational Structure                                       
               From December 22, 1988, to at least June 30, 1992 (a period            
          which includes petitioner's fiscal year ended April 30, 1991, the           
          year in issue), petitioner was a wholly owned subsidiary of ASAT,           
          Ltd., a Hong Kong corporation.  During its fiscal year ended                
          April 30, 1991, ASAT, Ltd., was 85 percent owned by a subsidiary            
          of QPL International Holdings Ltd. (QPL), a Bermuda corporation             
          with offices in Hong Kong.  Mr. Li Tung Lok (Mr. Li) was chairman           
          of the board and the largest single shareholder of QPL during               
          1990 and 1991.  Petitioner became 95 percent owned by Worltek               
          International Ltd. (Worltek), a domestic corporation organized in           
          California, when Worltek purchased 95 percent of petitioner's               
          stock directly from petitioner on July 15, 1992.   On November 9,           
          1994, QPL acquired 100 percent of the stock of Worltek.  Hence,             
          petitioner, once again, became an indirect subsidiary of QPL.               
          Petitioner's Business5                                                      
               Petitioner located semiconductor companies (customers) that            
          wanted their semiconductor dies put into an assembly package.               
          These customers contracted with petitioner for assembly services            


               5  Unless otherwise indicated, descriptions of petitioner's            
          business pertain to its fiscal year ending Apr. 30, 1991.                   



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