Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-structure-memo-338h10.docx
tax-structure-memo-338h10.docx
Parties
HARKNESS LLP
Ardent Capital Partners III LP
Luminex Systems Holdings Inc
Delaware General Corp
Ardent Apex Merger Sub Inc
Ardent Apex Holdings Inc
Associates LLP
Ardent Capital GP III LLC
Dates
March 24, 2025
June 14, 2021
March 5, 2025
March 7, 2025
December 31, 2024
April 15, 2026
Amounts
$2,800,000,000
$20.00
$405,020,000
$487,000,000
$121,800,000
$620,000,000
$8,680,000
$195,000,000
$15,000,000
$25,000,000
Obligations
Accordingly, the decision to proceed with the election must be made with careful consideration of all relevant factors, including the tax consequences to both the buyer and the sellers
The acquisition must constitute a "qualified stock purchase" within the meaning of Section 338(d)(3)
The target must be a domestic corporation (or, in the case of the selling group requirement, an S corporation)
The purchasing corporation must be a "corporation" for federal income tax purposes
The form must be signed by both the purchasing corporation (Ardent Apex Holdings Inc
Form 8023 must be filed no later than the fifteenth (15th) day of the ninth (9th) month beginning after the month in which the "acquisition date" (i