Skip to main content
Date
Rule
801.10, 801.13
Staff
Michael Verne
Response/Comments
Yes, for B as an acquired person, the transaction would be aggregated. N Ovuka concurs.

Question

From:(redacted)
Sent:Monday, December 06, 2004 6:12 PM
To:Verne, B. Michael
Subject: Partnership Interests

Mike,

In the proposed transactionA and B each own 50% of Partnership AB. B and C each own 50% of Partnership BC.A, B and C are separate persons for HSR purposes. A will buy the remaininginterests in Partnership AB and A will simultaneously buy 100% of the interestsin Partnership BC from B and C. A ends up owning 100% of the interests inPartnerships AB and BC.

My question is:do the two transactions have to be aggregated for purposes of determining thesize of transaction?

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. 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.

Learn more about Informal Interpretations.

Return to top