Extract to table

Second, the deferred tax liability arising from book-tax basis differences in the Solaris West solar PV assets must be properly reflected in the HLBV model to ensure that the hypothetical-liquidation distribution is consistent with the economic substance of the arrangement

The expected 2028 flip date, and the conditions that must be satisfied for the flip to occur (principally, Veltara Basin's achievement of its target after-tax IRR), are embedded in the HLBV model

Section 704(b) requires that partnership allocations have "substantial economic effect," which in practice means that the allocations must be consistent with the capital-account maintenance and liquidation-in-accordance-with-capital-accounts provisions of Treasury Regulations Section 1