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Contract analysis

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Contract analysis / submission-confirmation-email.eml
submission-confirmation-email.eml
1036-00006 · 6 clauses
High · 1 Medium · 1 Standard · 2
1. Private letter ruling request dated September 22, 2025, with penalties-of-perjury decla High
⚑ Penalty / liquidated damages
1. Private letter ruling request dated September 22, 2025, with penalties-of-perjury declaration, requesting three rulings under IRC §§ 856(c)(4)(B)(ii), 856(d), 856(d)(7)(B), and 856(d)(7)(C)(i) in connection with Fairwater's proposed acquisition of the Southgate Portfolio from Thornfield Development Group, LLC and the formation of Fairwater Southgate TRS, Inc.
2. Executed IRS Form 2848 (Power of Attorney and Declaration of Representative) designatin
2. Executed IRS Form 2848 (Power of Attorney and Declaration of Representative) designating Sylvia Hartwell (PTIN: P01882447) and Garrett Simmons (PTIN: P02094518) as authorized representatives, signed by Jonathan M. Hirota on behalf of Fairwater.
3. IRS user fee payment of $38,000 (Category 2, Specific Issues, per Rev. Proc. 2025-1, Ap Standard
⚑ Commercial term
3. IRS user fee payment of $38,000 (Category 2, Specific Issues, per Rev. Proc. 2025-1, Appendix A) — Ridgeline National Bank check no. 00471826, payable to "United States Treasury."
4. User fee transmittal letter. Standard
⚑ Commercial term
4. User fee transmittal letter.
5. All supporting exhibits, including: (a) organizational chart; (b) summary of the 11 Sou
5. All supporting exhibits, including: (a) organizational chart; (b) summary of the 11 Southgate Portfolio properties; (c) Caldwell Valuation Group appraisal summary; (d) proposed intercompany lease form; (e) REIT qualification metrics schedule; and (f) copy of Fairwater's Articles of Trust.
6. Required number of copies per Rev. Proc. 2025-1. Medium
⚑ Forum / governing law
6. Required number of copies per Rev. Proc. 2025-1. **Client Authorization** As a reminder, Jonathan's sign-off authorizing the submission was received on September 19, 2025, following the team's circulation of the draft ruling request on September 15. **Expected Next Steps and Timeline** - We anticipate receiving an IRS acknowledgment letter within 30–45 days of receipt of the submission. - Based on the subject matt