Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-protection-agreement.docx
tax-protection-agreement.docx
Parties
SOLSTICE PLATEAU ENERGY HOLDINGS LLC
Calloway-Briggs Renewables Inc
Lumen Ridge Infrastructure Partners LLC
Peachtree Corp
The LLC
Pennington Clarke LLP
Harkness LLP
Steele LLP
Dates
December 4, 2023
November 15, 2023
February 20, 2024
February 20, 2031
February 20, 2034
November 28, 2023
November 22, 2023
March 15, 2019
November 20, 2023
Amounts
$300,000,000
$150,000,000
$90,000,000
$87,000,000
$96,000,000
$34,200,000
$55,800,000
$60,000,000
$480,000,000
$5,000,000
Obligations
704-3(d), and that the Company shall maintain a capital account and tax allocation structure consistent therewith
For purposes of this Agreement, the following terms shall have the meanings set forth below
Capitalized terms used but not defined herein shall have the meanings ascribed to such terms in the LLC Agreement or the Contribution Agreement, as applicable
For the avoidance of doubt, the Adjusted Tax Basis of any individual Contributed Asset shall be its respective portion of the aggregate Adjusted Tax Basis as set forth on Schedule A hereto, as similarly adjusted from time to time
The aggregate Built-In Gain shall be reduced from time to time as provided in Section 3
Any reference to a provision of the Code shall include a reference to any successor provision thereto