Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-structuring-memo.docx
tax-structuring-memo.docx
Parties
Harkness LLP
Federal Inc
Solstice Plateau Energy Holdings LLC
Calloway-Briggs Renewables Inc
Lumen Ridge Infrastructure Partners LLC
Greystone Hamill LLP
Lumen Ridge Capital Advisors LLC
Whitmore Zanthor Group LLC
Dates
October 10, 2023
December 31, 2022
November 15, 2023
December 31, 2020
September 27, 2017
January 1, 2023
January 1, 2033
Amounts
$300,000,000
$150,000,000
$60,000,000
$90,000,000
$34,200,000
$55,800,000
$200,000,000
$400,000,000
$412
$98
Obligations
Under IRC §704(c), the JV must allocate this built-in gain to CBR when it is recognized through depreciation, amortization, or sale of the contributed assets
We must therefore analyze whether these management fees constitute disguised consideration for the contributed Project Portfolio
The JV must select one of these methods for the contributed Project Portfolio
In this simplified illustration, all $6,840,000 of actual tax depreciation is allocated to Lumen Ridge under the Section 704(c) principles (because CBR, as the contributing partner, must absorb the built-in gain, which effectively deprives CBR of tax depreciation on the contributed property)
The two categories of depreciation — (i) carryover basis depreciation subject to 704(c) and (ii) new construction depreciation shared equally — must be tracked separately on the JV's books and in the preparation of the Schedules K-1