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.

Learn more about Informal Interpretations.

Displaying 281 - 300 of 3961

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 below). The bulk of the...

1204010 Informal Interpretation

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

Response/Comments

- I think if you look back at the longstanding informal interpretations that we are responding to, it is implied, if not clearly stated, that not submitting a draft presupposes that a final version...

1204010 Informal Interpretation

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

Response/Comments

- I think if you look back at the longstanding informal interpretations that we are responding to, it is implied, if not clearly stated, that not submitting a draft presupposes that a final version...

1204009 Informal Interpretation

Staff:
Michael Verne
Rule:
801.1(a)(2)

Response/Comments

- No -that changed with the 2011 Form change rulemaking. An LLC engaged in commerce is treated the same as a corporation engaged in commerce, so any acquisition made through the LLC is reportable,...

1204009 Informal Interpretation

Staff:
Michael Verne
Rule:
801.1(a)(2)

Response/Comments

- No -that changed with the 2011 Form change rulemaking. An LLC engaged in commerce is treated the same as a corporation engaged in commerce, so any acquisition made through the LLC is reportable,...

1204005 Informal Interpretation

Staff:
Michael Verne
Rule:
15 USC 18a(c)(4) - 7A(c)(4)

Response/Comments

– Agree –Exempt under 18a(c)(4) - 7A(c)(4). No acquired person (see pt 6 of below / attached). DOJ concurs. 1 -The government is not an entity as defined in §801.1(a)(2) 2 -Therefore, it cannot be an...

1204005 Informal Interpretation

Staff:
Michael Verne
Rule:
15 USC 18a(c)(4) - 7A(c)(4)

Response/Comments

Agree Exempt under 18a(c)(4) - 7A(c)(4). No acquired person (see pt 6 of below / attached). DOJ concurs. 1 -The government is not an entity as defined in 801.1(a)(2) 2 -Therefore, it cannot be an...

1204003 Informal Interpretation

Staff:
Michael Verne
Rule:
802.30

Response/Comments

This is not exempt under 802.30, 802.30(a) reads - (a) An acquisition ... in which the acquiring and at least one of the acquired persons are, the same person by reason of 801.1(b)(1) of this chapter...

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