1303007 Informal Interpretation

Michael Verne

Yes- but
only to the extent they are non-duplicative. E.g., if a sale is made from a foreign
sub to a US sub and then
sold on by the US sub,
you would count the following:
Sales by the US sub to US customers (do not include
the sale by the
foreign sub to the US sub on these sales)
- Sales by the foreign sub to the US sub (for export
sales by the US
sub, which are not counted)


From: (Redacted)

Sent: Tuesday, March 2.6, 2.013 2:47 PIVJ

To:Verne, B. Michael

Subject: RE: Interps207 and 242. in Manual

Under 802.51, do sales into theUS include intra company sales?

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Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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