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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8303008 Informal Interpretation

Staff:
Roberta Baruch
Rule:
801.40

Response/Comments

If any of the individuals involve in this transaction meets the size-of-person test and size-of-transaction test then it is probably reportable. Since the ban has $55 million in assets, the$10...

9012009 Informal Interpretation

Staff:
Nancy Ovuka
Rule:
802.1(a)

Response/Comments

Conclusion correct, but not for reasons cited. Exempt as realty in the ordinary course. Income stream incidental to sale of property & business of partnership which isdevelopment. Golf course...

1610004 Informal Interpretation

Staff:
Ty Carson
Rule:
Item 5

Response/Comments

In this tolling agreement scenario, Company A should report in Item 5 the revenue for any sales that appear on the books of the US business of Company A, and do so using a wholesale NAICS Code.

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