Defining Gifts, Meals, Entertainment, Travel and Hospitality

Let's go to the next slide and take a look at some of the definitions that we work with. When we say gifts, we mean obviously items given to a third party on behalf of the company. That includes down to the hat or the pen, that includes your logo on it. That is considered a gift. Obviously it's of a nominal value, but it extends all the way up to Mooncakes, our favorite Mooncakes in China, and other types of more lavish type of gifts when appropriate. Meals, obviously is taking people out. If you're attending as your company representative, then it's not a gift, it's a meal, in terms of that. On the other hand, if you give them a certificate to go eat a restaurant, or to pay for a meal somewhere, then it's a gift.

Entertainment obviously, events, concerts, sporting events in particular, we see a lot of that, and payment for transportation or lodging, and that sort of lodging I think goes a little bit more in hospitality. Nonetheless, receptions that are conducted and hosted by the company at a trade show or conference, and you bring people let's say into a room just to talk about your particular product.

 This webinar was co-hosted with Michael Volkov of VolkovLaw.