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Date
Rule
Item 5(a)
Staff
Nora Whitehead
Response/Comments

Yes.

Question

From: Whitehead, Nora <nwhitehead@ftc.gov>
Sent: Thursday, July 14, 2022 3:59:48 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: Item 5(a) and natural person

Yes.

From: [Redacted]
Sent: Thursday, July 14, 2022 1:48:39 PM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: Item 5(a) and natural person

I had received guidance a few years ago that a natural person UPE who is also a foreign person would only need to report investment income under Item 5(a) for investments made through a US broker. Is that still the case if the natural person UPE resides outside the US, but still happens to be a US citizen?

About Informal Interpretations

Informal interpretations provide guidance from PNO staff on the applicability of the HSR rules to specific fact situations. They do not necessarily reflect the position of the Commission. 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.

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