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You should value everything that is being acquired that is not exempt. Any rental relationship between the targets is not relevant for HSR analysis. See 803.9(c).

You should report the codes in Item 5, along with an explanation about the negative revenue, and Item 7 information if any of the codes capture overlaps.

We typically see both spouses listed as the UPE, but only one of them has to sign.

While we agree that these do not appear to be sales in or into the US, you have all the facts and will need to make the final call on the analysis (and be prepared to defend it should the agency...