FR EA

Extract to table

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

Extract to table / cv-lpa-tax-provisions-markup.docx
cv-lpa-tax-provisions-markup.docx · 1002-00005

Parties

OF PINNACLE CONTINUATION VEHICLE LP
Harkness LLP
Hawthorne Reid LLP
Partner Hawthorne Reid LLP
Partner Pinnacle Capital Management LLC
Pinnacle Capital Management LLC
Pinnacle Continuation Vehicle LP
Draft LP

Dates

July 28, 2025
August 8, 2025
October 31, 2028
June 30, 2025
June 15, 2025
December 31, 2017
September 22, 2025
October 31, 2025
September 30, 2025

Amounts

$1.202
$1,340,000,000
$138
$50
$75,000,000
$250
$250,000,000
$1,074,000,000
$50,000,000
$58,500,000

Obligations

Unless otherwise defined herein, capitalized terms used in this Article shall have the meanings ascribed to them in Article I of the Agreement
Any reference herein to a specific section of the Code shall include any successor provision thereto and any Treasury Regulation promulgated thereunder
The Partnership shall establish and maintain a separate Capital Account for each Partner in accordance with Treasury Regulation Section 1
The Capital Accounts shall be maintained for the full term of the Partnership and through the completion of the liquidation and winding up of the Partnership's affairs
Each Partner's Capital Account shall be credited with: (i) the amount of cash actually contributed by such Partner to the Partnership; (ii) the fair market value of any property contributed by such Partner to the Partnership (net of any liabilities secured by such property that the Partnership is considered to assume or take subject to under Section 752 of the Code), as determined by the General Partner in good faith; provided that, with respect to the Contributed Assets, the fair market value shall be the Book Value thereof as set forth in the definition of "Book Value" in Section X
In the event of a transfer of all or a portion of a Partner's interest in the Partnership in accordance with the terms of this Agreement, the transferee shall succeed to the Capital Account of the transferor to the extent it relates to the transferred interest