Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / fin-48-reserve-update-post-settlement.docx
fin-48-reserve-update-post-settlement.docx
Parties
Harkness LLP
Global Tax Penterra Pharmaceuticals Corp
General Counsel Penterra Pharmaceuticals Corp
Financial Officer Penterra Pharmaceuticals Corp
Penterra Pharmaceuticals Corp
Whitmore Valuation Group LLC
Associates LLP
IP-Holding Structure Penterra Pharmaceuticals Corp
Dates
March 30, 2024
September 20, 2022
November 20, 2023
March 29, 2024
December 31, 2024
December 31, 2020
March 15, 2012
July 1, 2012
May 16, 2022
June 2, 2022
Amounts
$62.4
$14.8
$47.6
$380.4
$10.0
$2.84
$12.84
$8.33
$5,837,420
$2,146,800
Obligations
Under ASC 740-10-25, a tax position must first be evaluated to determine whether it is "more likely than not" (i
If the threshold is not met, no tax benefit is recognized, and the entire tax benefit associated with the position must be reserved
Reassessment Triggering Events Under ASC 740-10-25-14, an entity is required to reassess its unrecognized tax benefits at each reporting date based on new information that may bear on the recognition or measurement of the tax positions
Accordingly, the UTP reserve attributable to TY 2017–2020 must be de-recognized and replaced with the known settlement amount
Because the Closing Agreement constitutes a conclusive and binding resolution of all uncertainty with respect to the TY 2017–2020 transfer pricing positions, the UTP reserve attributable to those years must be fully de-recognized under ASC 740-10-25-14
Accordingly, the UTP reserve must be replaced with the actual settlement liability