USA Law and Practice Contributed by: Bradley Justus, Lisl Dunlop, Josh Jowdy and Sandhya Taneja, Axinn
tions” as may be defined by revised OISP regulations; (i) intercompany transfers; and (j) any transaction completed before the date of the enactment of the title. The COINS Act requires the US Treasury to issue regulations within 450 days of its enactment, which is March 2027. Foreign Merger Subsidy Disclosure Act Under the Foreign Merger Subsidy Disclosure Act (FMSDA), signed into law in December 2022, parties filing pre-merger notifications under the HSR Act will be required to disclose information about subsidies they receive from “foreign entities of concern”, such as entities controlled by China, Iran, North Korea, Russia, and other entities included on the Special - ly Designated Nationals and Blocked Persons List (SDN). FMSDA disclosures had been included in the suspended 2025 HSR notification form; there are cur - rently no processes in place for FMSDA notification.
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