The Company was a shell prior to 2015. That is nor correct that the TA is covered by a simple legal opinion. The holding period is 2 years - it is a very simple and VERY SETTLED legal concept
Correct. They cured the shell status and Anastasia transferred her shares to the new puppets. Per SEC rules, the holding period is still when she got the shares!
So even if her shares were subject to the two year holding period, it is now well past.