Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / post-closing-tax-integration-memorandum.docx
post-closing-tax-integration-memorandum.docx
Parties
Harkness LLP
Ardent Capital Partners III LP
Pinnacle Health Services Group LLC
DeVries LLP
Ardent Healthcare Merger Sub LLC
Ardent Healthcare Holdings LLC
Ardent Healthcare Intermediate Inc
Holdings LLC
Dates
June 14, 2024
May 31, 2024
March 15, 2024
May 10, 2024
June 30, 2024
August 12, 2016
December 31, 2024
May 28, 2024
June 28, 2024
March 15, 2025
Amounts
$412
$339.4
$35.0
$198.5
$59.54
$30
$224.4
$412.0
$187.6
$20.04
Obligations
as a newly formed C-corporation, must compute and remit quarterly estimated federal and state income tax payments
Tax distribution obligations from Holdings LLC to its members must also be coordinated
Coordination and Filing Caldwell Pratt & Moorehouse LLP will be responsible for preparing Pinnacle's 2024 Form 1065, to which the Section 754 election statement must be attached
The election must be signed by a partner authorized to make elections on behalf of the partnership
Given the nature of Pinnacle's assets — which include accounts receivable, supplies inventory, and intangible assets that may constitute unrealized receivables within the meaning of Section 751(c) — Form 8308 is required to be filed for the taxable year that includes the closing date (2024)
Form 8308 must be filed as an attachment to Pinnacle's 2024 Form 1065