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Date
Rule
Form: Transaction Information
Staff
Premerger Notification Office
Response/Comments

If the to-be-formed entity will be merged into the target with the target surviving, you only need to list Firm A as the acquiring entity.

Question

I have a situation where Firm A has signed an LOI to acquire Target B. We plan on filing under the LOI. Firm A is controlled by UPE. For tax reasons, Firm A will create a to be formed entity that will be wholly owned by Firm A to make the acquisition of Target B at closing. The UPE is the acquiring person so it is the UPE’s filing, but Firm A is the business that is making the acquisition through the to be formed entity. In this situation, when I list the parties, I list UPE as the Acquiring person, and for the acquiring entity, I would list the “to be formed entity”. But, would I also list Firm A’s information as an acquiring entity?

In the transaction description, I plan to explain all of this, but for purposes of completing the form, affidavit and certification, I was going to have Firm A file on behalf of the UPE, and Firm A’s executive sign the affidavit and certification page.

Also for the business of the acquiring person, I plan to explain Firm A’s business.

Let me know if I should list both A and to be formed entity as acquiring entities or just the to be created entity.

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. 

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