Informal Interpretations

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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Displaying 261 - 280 of 3961

1205009 Informal Interpretation

Staff:
Michael Verne
Rule:
802.65

Response/Comments

- This sounds vaguely like the other transaction you had a few weeks ago with a control issue involving 802.65. In this scenario, however, you made it clear that the overarching rationale behind the...

1205010 Informal Interpretation

Staff:
Michael Verne
Rule:
801.2, 802.4, 801.10, 801.13

Response/Comments

- Is the 49% interest in Target LLC the only holding of D Corp.? If so, the acquisition of the voting securities of D Corp. is exempt under 802.4. If the value of the assets of X Corp. is less than $...

1205010 Informal Interpretation

Staff:
Michael Verne
Rule:
801.2, 802.4, 801.10, 801.13

Response/Comments

- Is the 49% interest in Target LLC the only holding of D Corp.? If so, the acquisition of the voting securities of D Corp. is exempt under § 802.4. If the value of the assets of X Corp. is less than...

1205009 Informal Interpretation

Staff:
Michael Verne
Rule:
802.65

Response/Comments

- This sounds vaguely like the other transaction you had a few weeks ago with a control issue involving 802.65. In this scenario, however, you made it clear that the overarching rationale behind the...

1205005 Informal Interpretation

Staff:
Michael Verne
Rule:
801.1(b)

Response/Comments

- This sounds like series LLCs which we have dealt with recently. You are right, the different series of units are not separate legal entities, so you would look at whether anyone has the right to 50...

1205005 Informal Interpretation

Staff:
Michael Verne
Rule:
801.1(b)

Response/Comments

- This sounds like series LLCs which we have dealt with recently. You are right, the different series of units are not separate legal entities, so you would look at whether anyone has the right to 50...

1205006 Informal Interpretation

Staff:
Michael Verne
Rule:
801.11

Response/Comments

- You have it right on how to consolidate Parent and Subsidiary. On which financials to use, if the monthly reports of Subsidiary are deemed to be regularly prepared, it doesnt matter that they are...

1205002 Informal Interpretation

Staff:
Michael Verne
Rule:
802.2(c)(1)

Response/Comments

- I think the revenues that C gets from selling the logs to third parties should be excluded. The only revenues generated by A/timberlands is the payments by C under the cutting contract. The...

1205002 Informal Interpretation

Staff:
Michael Verne
Rule:
802.2(c)(1)

Response/Comments

- I think the revenues that C gets from selling the logs to third parties should be excluded. The only revenues generated by A/timberlands is the payments by C under the cutting contract. The...

1205001 Informal Interpretation

Staff:
Michael Verne
Rule:
Form Item 4(c)

Response/Comments

The third paragraph from the end which begins "Other informal staff opinions" addresses the "two hats" interpretation which is no longer our position (see attached). The bulk of...

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