Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / form-906-closing-agreement-draft.docx
form-906-closing-agreement-draft.docx
Parties
HARKNESS LLP
Penterra Pharmaceuticals Corp
Corporation Inc
Penterra Manufacturing Ireland Ltd
Associates LLP
Whitmore Valuation Group LLC
Taxable Inc
Ireland Inc
Dates
March 22, 2024
March 15, 2024
February 28, 2024
March 29, 2024
December 31, 2017
December 31, 2018
December 31, 2019
December 31, 2020
June 8, 2022
May 16, 2022
Amounts
$312,000,000
$188,032,000
$188,040,000
$42,650,000
$15,977,000
$380,400,000
$47,600,000
$11,200,000
$12,400,000
$12,800,000
Obligations
The exact amount of interest will be determined by the IRS at the time of assessment and billing and shall be paid by PPC in accordance with applicable law
Accordingly, no penalty under IRC § 6662(e), or any other penalty provision of the Code, shall be assessed or collected with respect to the adjustments covered by this Agreement
Similarly, nothing in this Agreement shall affect, limit, or prejudice the IRS's right to examine, challenge, or propose adjustments to PPC's transfer pricing for such other tax years
PPC shall file amended federal income tax returns on Form 1120X (Amended U
Such amended returns shall be filed with the Internal Revenue Service within ninety (90) days of the date of execution of this Agreement by all parties
PPC shall make payment of all additional federal income tax and interest due as computed under Sections 3