Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-structure-memo-ccorp-upc.docx
tax-structure-memo-ccorp-upc.docx
Parties
Harkness LLP
Calloway-Briggs Renewables Inc
Associates LLP
CBR Holdings LLC
Calloway-Briggs Operating Company LLC
Solaris West Solar LLC
Veltara Basin Financial LLC
Current Corp
Dates
March 28, 2022
December 31, 2021
April 11, 2022
Amounts
$600,000,000
$1.5
$3.0
$487.3
$218.6
$41.7
$3.94
$1.71
$4.8
$385
Obligations
No restructuring is required to proceed with a C-corp IPO
These costs and delays must be weighed against the incremental tax benefits of an Up-C structure, which are analyzed in Section IV
Diluted earnings per share ("EPS") calculations must account for the potential exchange of OpCo units into PubCo common stock