Extract to table

This strategy must be evaluated carefully to ensure that it is respected by the Philadelphia Department of Revenue under economic substance and anti-avoidance doctrines

Coordination with the following parties is required to ensure proper treatment of withholding amounts in the closing funds flow: • Ironbridge Trust Company, N

(administrative agent under the credit agreement): Coordination with the administrative agent is required to ensure that the withholding amounts are properly deducted from the equity consideration before the remaining net proceeds are distributed to sellers

The Section 754 election must be properly documented and attached to the timely filed (including extensions) partnership return