Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-considerations-memo.docx
tax-considerations-memo.docx
Parties
HARKNESS LLP
Verimark Hospitality Group Inc
Greystone Federal Credit Corp
Wharton LLP
Meridian Strauss Advisory LLC
Partridge LLP
Federal Inc
Dates
February 14, 2020
December 31, 2022
February 14, 2027
July 21, 2022
March 29, 2022
July 21, 2029
December 31, 2021
December 31, 2017
January 1, 2022
April 18, 2022
Amounts
$625,000,000
$700,000,000
$3,125,000
$7,000,000
$1.42
$341
$621,875,000
$400,000,000
$245,000,000
$1.27
Obligations
446-5, debt issuance costs — that is, costs incurred by the borrower in connection with the borrowing of money — must be capitalized and amortized over the term of the debt instrument to which they relate
The maturity test alone does not trigger AHYDO classification; both remaining tests must also be met
For AHYDO purposes, however, the YTM must be computed using the issue price of $693,000,000 (rather than par) and all scheduled payments of principal and interest
Test 3 — Significant OID Because the AHYDO tests are cumulative — all three must be met for AHYDO classification to apply — and Test 2 has not been satisfied, it is not strictly necessary to analyze Test 3
The estimated unamortized balance of the original debt issuance costs is therefore: $7,000,000 × (55 months remaining ÷ 84 months total) ≈ $4,583,333 (illustrative) If the Existing TLB was issued with OID (which we have not been able to confirm from the documents currently available), any remaining unamortized OID from the 2020 issuance must also be addressed
Coordination with New Facility Costs It is important to emphasize that the unamortized debt issuance costs from the Existing TLB and the new debt issuance costs associated with the New TLB must be tracked independently