FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / tax-structure-memorandum-pinnacle-cv.docx
tax-structure-memorandum-pinnacle-cv.docx · 1002-00005

Parties

MEMORANDUM PINNACLE CONTINUATION VEHICLE LP
HARKNESS LLP
Pinnacle Continuation Vehicle LP
Pinnacle Venture Fund II LP
Pinnacle Capital Management LLC
Luminos Systems Inc
ClearArc Software Inc
Vectral Cloud Inc

Dates

July 15, 2025
October 31, 2025
June 30, 2025
September 15, 2025
October 31, 2030
September 27, 2010
January 1, 2013

Amounts

$612
$468
$260
$1.34
$138
$1.202
$1.074
$680
$380
$14

Obligations

As discussed in detail in Section V below, the CV structure must be carefully designed to ensure that the holding period tacks through the transfer to the CV so that the March 2026 date is not reset
Further diligence is required to confirm that Vectral's gross assets did not exceed this threshold at the time of issuance
To qualify as QSBS under Section 1202, stock must satisfy all of the following requirements: (a) Domestic C-Corporation
The stock must be stock of a domestic C-corporation
The stock must be acquired by the taxpayer at its original issuance (directly or through an underwriter), in exchange for money, property (other than stock), or services
At the time of issuance, the corporation must be a "qualified small business," meaning its aggregate gross assets did not exceed $50 million (including the amount received in the issuance)