Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / dd-memo-tax-structure.docx
dd-memo-tax-structure.docx
Parties
Harkness LLP
Calloway-Briggs Renewables Inc
Veltara Basin Financial LLC
Associates LLP
Pemberton LLP
CBR Holdings LLC
Delaware LLC
Calloway-Briggs Operating Company LLC
Dates
April 25, 2022
September 15, 2014
March 28, 2022
December 31, 2021
September 27, 2017
December 31, 2017
December 31, 2020
October 15, 2020
October 15, 2023
April 1, 2022
Amounts
$600,000,000
$0.01
$187.3
$261.8
$83.2
$28.6
$29.1
$47.3
$22.4
$8.7
Obligations
The pre-IPO holders and PubCo typically enter into a tax receivable agreement ("TRA"), under which PubCo agrees to pay the pre-IPO holders a specified percentage (typically 85%) of the tax savings realized as a result of the basis step-up
Receipt of this confirmation is a condition that must be satisfied prior to the pricing of the offering
The tax-equity investor must make a minimum unconditional investment of at least 20% of its total investment at the time of closing
The tax-equity investor must bear meaningful downside risk with respect to its investment
The flip must occur upon the tax-equity investor's achievement of a target yield (i