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his family’s relocation from Paris to Massachusetts. Petitioner
ceased actively working for and receiving a salary from Millipore,
S.A.; he did, however, continue to receive a French pension. (On
February 2, 1996, petitioner became a U.S. citizen.) In his new
position, petitioner managed the sales operations of Millipore’s
subsidiaries. Approximately 2 years later, petitioner was promoted
to president of Millipore’s analytical group.
On December 22, 1989, petitioner was promoted to president of
MilliGen/Biosearch, a startup division of Millipore (with $16
million in sales and $20 million in losses). This promotion was
announced in a general distribution memorandum, which stated in
relevant part:
This election is evidence of the critical role Alain
plays in the leadership of the corporation, and of the
diverse management responsibilities he has successfully
undertaken in his many years of service with Millipore.
He has been an important leader directing the evolution
of our European business. He has also been instrumental
in the success of the Analytical Group, where he
strengthened the management team and helped groom his own
successor as president. And now, as president of
MilliGen/Biosearch, he has assumed one of our most
difficult managerial assignments in a business that is
vital to our future.
On August 23, 1991, petitioner was promoted to Millipore’s
corporate vice president of marketing. Petitioner was responsible
for marketing, promotion, public relations, merger and
acquisitions, new business development, and long-range planning for
the entire company. (Petitioner held this position at the time he
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