1403005 Informal Interpretation



Michael Verne

If it is a 55% undivided interest in the reserves, you would look at 55% of the value of the total reserves. If it is a 55% interest in an entity that holds the reserves: you would be under §802.4, so you would look at the value of 100% of the underlying reserves


From: Gillis, Diana L.
Sent: Thursday, March 13, 2014 11:30 AM
To: Verne, B. Michael
Subject: 802.3

Hi Mike- quick 802.3 valuation question- if a company is buying a 55% interest in oil reserves, is the relevant value to consider just the 55% (versus the value for 100% of the reserves)?

Diana Gillis
Premerger Notification Office
Federal Trade Commission
(202) 326-2220  dgillis@ftc.gov

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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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