0009007 Informal Interpretation

us-ftc-hsr-informal-interpretations-3037fa1b6c9b252c851062762a2b37df0009007 Informal InterpretationGuidance

Date
Rule
802.4
Staff
Michael Verne
Response/Comments
Company A acquiring partnership B: - 100% interests - look through to underlying assets - minority interest - exempt regardless of underlying assets Partnership B acquiring Company A - minority or controlling interest: look to underlying assets to determine exempt.

Question

From: (redacted)

To: "mverne@ftc.gov" <mverne@ftc.gov>

Date: Wed, Sep 20, 2000 11:29 AM

Subject: HSR follow-up.

Thank you for your advice. Subsequently to our conversation, I learned that both Company a and Partnership B have investments in other homebuilding partnerships or LLCs - all of whose assets would be exempt. Since these are partnership interests, I could not find an exemption. If the value of each of these interests were in excess of $15MM would filing be required, or is there another exemption that would apply. Thanks.

cc: (redacted)

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