us-ftc-hsr-informal-interpretations-0b531fabb139c26e381b2d04bcbaf6c1•1606004 Informal Interpretation
1606004 Informal Interpretation
us-ftc-hsr-informal-interpretations-0b531fabb139c26e381b2d04bcbaf6c11606004 Informal InterpretationGuidance
Tags:
The identity of the customer is irrelevant.
If shipping from the US, count in Item 5.
If shipping from a foreign location to the US, don’t count in Item 5, unless the sale is booked by a US entity.
If shipping from a foreign location to a foreign location, don’t count in Item 5, unless the sale is booked by a US entity.
Question
From: Gillis, Diana L.
Sent: Wednesday, June 22, 2016 1:19 PM
To: [REDACTED]
Cc: [REDACTED]; Walsh, Kathryn E.; Berg, Karen E.; Whitehead, Nora; Storm, Evan; Shaffer, Kristin; Carson, Timothy
Subject: RE: HSR Item 5
The identity of the customer is irrelevant.
If shipping from the US, count in Item 5.
If shipping from a foreign location to the US, don’t count in Item 5, unless the sale is booked by a US entity.
If shipping from a foreign location to a foreign location, don’t count in Item 5, unless the sale is booked by a US entity.
From: [REDACTED]
Sent: Monday, June 20, 2016 4:43 PM
To: Walsh, Kathryn E.; Berg, Karen E.; Gillis, Diana L.; Whitehead, Nora
Cc: [REDACTED]
Subject: HSR Item 5
Dear all,
We had a question concerning how to account for certain revenues in Item 5 of the HSR Form for a foreign multinational shipping company. We reviewed informal interpretation 1408005 but the hypothetical addressed was limited to non-US customers. Does the PNO have a general approach for revenue derived from shipping to and from the US when a shipping company contracts with a US customer?
Thank you very much.
Best regards,
REDACTED]
From: Gillis, Diana L. To: Cc: Walsh, Kathryn E.; Berg, Karen E.; Whitehead, Nora; Storm, Evan; Shaffer, Kristin; Carson, Timothy Subject: RE: HSR Item 5 Date: Wednesday, June 22, 2016 1:19:00 PM Attachments: image001.jpg The identity of the customer is irrelevant. If shipping from the US, count in Item 5. If shipping from a foreign location to the US, don’t count in Item 5, unless the sale is booked by a US entity. If shipping from a foreign location to a foreign location, don’t count in Item 5, unless the sale is booked by a US entity. From: Sent: Monday, June 20, 2016 4:43 PM To: Walsh, Kathryn E.; Berg, Karen E.; Gillis, Diana L.; Whitehead, Nora Cc: Subject: HSR Item 5 Dear all, We had a question concerning how to account for certain revenues in Item 5 of the HSR Form for a foreign multinational shipping company. We reviewed informal interpretation 1408005 but the hypothetical addressed was limited to non-US customers. Does the PNO have a general approach for revenue derived from shipping to and from the US when a shipping company contracts with a US customer? Thank you very much. Best regards,
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