15100001 Informal Interpretation

us-ftc-hsr-informal-interpretations-52922fd6820db0fd203fe47bb273100d15100001 Informal InterpretationGuidance

Open source
Date

Tags:

Rule
7A(c)(1)
Staff
Nora Whitehead
Response/Comments

The REIT Exemption, 7A(c)(1), does not extend to foreign REITs.

Question

From: Whitehead, Nora
Sent: Friday, October 16, 2015 1:46 PM
To: [REDACTED]
Cc: Walsh, Kathryn E.; Gillis, Diana L.
Subject: RE: REIT Exemption

As of right now, we are not prepared to extend the REIT exemptions to foreign REITs.

Nora Whitehead

(202) 326-3262

Check out the PNO Blog!

From: [REDACTED]
Sent: Friday, October 16, 2015 1:28 PM
To: Walsh, Kathryn E.; Berg, Karen E.; Gillis, Diana L.; Whitehead, Nora
Subject: REIT Exemption

Hi all – Would the PNO treat non-US REITs the same as US REITS for the purposes of the “REIT Exemption”? The foreign REIT would be in the business of buying, owning, leasing and selling real property. I couldn’t find any guidance online.

Many thanks,

[REDACTED]

1
From: 	Whitehead, Nora
Sent: 	Friday, October 16, 2015 1:46 PM
To:
Cc: 	Walsh, Kathryn E.; Gillis, Diana L.
Subject: 	RE: REIT Exemption
As of right now, we are not prepared to extend the REIT exemptions to foreign REITs.
Nora Whitehead
(202) 326‐3262
Check out the PNO Blog!
From:
Sent: Friday, October 16, 2015 1:28 PM
To: Walsh, Kathryn E.; Berg, Karen E.; Gillis, Diana L.; Whitehead, Nora
Subject: REIT Exemption
Hi all – Would the PNO treat non-US REITs the same as US REITS for the purposes of the “REIT
Exemption”? The foreign REIT would be in the business of buying, owning, leasing and selling real
property. 	I couldn’t find any guidance online.
Many thanks,
Complete printed PDF page 1

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