Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / draft-tax-opinion-section-721.docx
draft-tax-opinion-section-721.docx
Parties
HARKNESS LLP
Pinnacle Capital Management LLC
Pinnacle Venture Fund II LP
Pinnacle Capital Partners II LLC
Federal Inc
Pinnacle Continuation Vehicle LP
Pinnacle CV Partners LLC
Luminos Systems Inc
Dates
October 31, 2025
July 15, 2025
June 30, 2025
September 15, 2025
September 22, 2025
December 31, 2024
December 31, 2020
Amounts
$875,000,000
$831,250,000
$1,820,000,000
$1,560,000,000
$58,500,000
$2,480,000,000
$612,000,000
$553,500,000
$37,400,000
$1,500,000,000
Obligations
The CV's aggregate basis of $138,000,000 in Portfolio Company interests valued at $1,340,000,000 will give rise to significant Section 704(c) built-in gain that must be allocated in accordance with the methodology adopted in the CV LPA (discussed in Section V
Section 707(a)(2)(B) — Disguised Sales Section 707(a)(2)(B) of the Code provides that, under regulations prescribed by the Secretary of the Treasury, if a partner transfers property to a partnership and there is a related direct or indirect transfer of money or other property by the partnership to such partner, and when viewed together the transfers are properly characterized as a sale or exchange of property, then such transfers shall be treated as a transaction between the partnership and a person who is not a partner