Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-structuring-memorandum.docx
tax-structuring-memorandum.docx
Parties
Harkness LLP
Genome Dx Therapeutics Inc
Federal Inc
Lane LLP
Gregg LLP
Dates
May 5, 2023
September 12, 2019
August 8, 2025
August 8, 2026
August 8, 2024
February 8, 2025
August 8, 2023
December 31, 2023
December 6, 2023
November 6, 2023
Amounts
$140,000,000
$126,000,000
$14,000,000
$312,000,000
$47,600,000
$4.2
$8,000,000
$6,000,000
$52,600,000
$28,600,000
Obligations
The actual depreciation history of GDT's leasehold improvements must be confirmed with the GDT finance team and Haverford & Lane LLP
The allocation reported on each party's Form 8594 must be consistent; if the parties agree on the allocation, both should report the same figures
The APA further provides that, if the parties agree on the allocation, both parties shall report the transaction on their respective tax returns in a manner consistent with the agreed-upon allocation and shall not take any position inconsistent therewith in any tax proceeding, audit, or examination
Escrow Treatment The $14,000,000 escrow deposit must be distinguished from the earnout for tax purposes