2508006 Informal Interpretation

us-ftc-hsr-informal-interpretations-e96d9b42718818bcc4c12d195b9b38f22508006 Informal InterpretationGuidance

Date
Rule
Form: Transaction Information
Staff
Premerger Notification Office
Response/Comments

If the to-be-formed entity will be merged into the target with the target surviving, you only need to list Firm A as the acquiring entity.

Question

I have a situation where Firm A has signed an LOI to acquire Target B. We plan on filing under the LOI. Firm A is controlled by UPE. For tax reasons, Firm A will create a to be formed entity that will be wholly owned by Firm A to make the acquisition of Target B at closing. The UPE is the acquiring person so it is the UPE’s filing, but Firm A is the business that is making the acquisition through the to be formed entity. In this situation, when I list the parties, I list UPE as the Acquiring person, and for the acquiring entity, I would list the “to be formed entity”. But, would I also list Firm A’s information as an acquiring entity?

In the transaction description, I plan to explain all of this, but for purposes of completing the form, affidavit and certification, I was going to have Firm A file on behalf of the UPE, and Firm A’s executive sign the affidavit and certification page.

Also for the business of the acquiring person, I plan to explain Firm A’s business.

Let me know if I should list both A and to be formed entity as acquiring entities or just the to be created entity.

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