" Good question. I don't think so, though I think the seller would have to meet certain tests so that they are not making an "offer" of shares under certain definitions."

We know the current BODS of khc would like to see the brk shares of khc in, friendly hands. IF khc doesn't have 3-8 billion sitting around to buy all or a piece of the block they are at Buffett's mercy, with respect to who brk sells the block too.

For years Buffett has bought back blocks of brka from old friends who have held the shares of brkb for decades. Obviously, the lawyers signed off on these transactions, but, imo, brka should have disclosed the terms of the sales and offered the same price to any willing sellers.

It's hard to say what the regs are today but I'm sure brk is always in full compliance.