For purposes of 802.50 and 802.51, the accounts receivable should be attributed to the jurisdiction in which they were entered into.
Question
From: Shaffer, Kristin <kshaffer@ftc.gov>
Sent: Monday, January 22, 2024 1:50:22 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: Location of AR Inquiry
[Redacted]
For purposes of 802.50 and 802.51, the accounts receivable should be attributed to the jurisdiction in which they were entered into.
Best regards,
Kristin
From: [Redacted]
Sent: Friday, January 19, 2024 1:02:58 AM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: Location of AR Inquiry
Dear PNO,
I have (hopefully) a quick question. We are assessing the HSR reportability of a transaction and a question has come up about the location of the target’s accounts receivable. Researching the informal interpretations, I found (https://www.ftc.gov/legal-library/browse/hsr-informal-interpretations/9504003), which states that the location of the accounts receivable is not the jurisdiction of the debtor, but the physical location of the AR (Census approach).
My question is what “ physical location of the AR (Census approach)” means. Is this the physical location of the AR holder, or something else?
Many thanks and please let me know if I can provide any additional detail in connection with this inquiry.