Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / cut-analysis-royalty-report.docx
cut-analysis-royalty-report.docx
Parties
Penterra Pharmaceuticals Corp
Whitmore Valuation Group LLC
Harkness LLP
Associates LLP
Framework Whitmore Valuation Group LLC
Fenmore Services Inc
Overview Penterra Pharmaceuticals Corp
Penterra Manufacturing Ireland Ltd
Dates
July 1, 2012
June 20, 2022
October 12, 2023
November 8, 2023
March 15, 2012
Amounts
$188,040,000
$380.4
€47.2
$6.82
$1.47
€2.14
€1.06
$814.6
$624.1
$130.18
Obligations
PBI has limited sublicensing rights subject to PPC's prior written consent, which shall not be unreasonably withheld
Thus, while the IRS is authorized to make adjustments to clearly reflect income, any such adjustment must itself produce a result that is consistent with what unrelated parties would have agreed to under comparable circumstances
482-4(c)(2) identifies the factors that must be considered in evaluating the comparability of uncontrolled transactions to the controlled transaction for purposes of the CUT method
The intangible property involved in the uncontrolled transaction must be comparable to the intangible property involved in the controlled transaction
The circumstances of the uncontrolled transaction must be comparable to those of the controlled transaction