Our views are still consistent with Interpretation #151 in the latest edition of the Premerger Notification and Practice Manual.
Question
From: Shaffer, Kristin
Sent: Thursday, September 6, 2018 3:19:34 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: [Redacted}
Subject: RE: 802.51
[Redacted]
Our views are still consistent with Interpretation #151 in the latest edition of the Premerger Notification Practice Manual.
Best regards,
Kristin
From: [Redacted}
Sent: Thursday, September 06, 2018 10:36 AM
To: [Redacted]
Subject: 802.51
Dear HSR Team:
Are intercompany sales between or among the foreign parent and its U.S. subs or affiliates included in the total sales “in or into the United States” under 802.51? I have a foggy memory that the PNO view on this issue might have changed, but I cannot find a clear statement or anything in our notes here.
Thank you for your assistance.