FR EA

Extract to table

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

Extract to table / tax-opinion.docx
tax-opinion.docx · 1021-00002

Parties

HARKNESS LLP
Verimark Hospitality Group Inc
Federal Inc
Ridgeline Capital Markets LLC
Stonebridge Marvelo Securities Inc
Howe LLP
Income Inc

Dates

June 25, 2024
July 1, 2031
June 18, 2024
January 1, 2025
June 14, 2024
May 1, 2024
December 31, 2023
December 31, 2022
December 31, 2021
January 1, 2022

Amounts

$500,000,000
$492,500,000
$7,500,000
$8,750,000
$483,750,000
$1,000
$985
$412,000,000
$15.00
$17.50

Obligations

1273-1(d), if the OID on a debt instrument is less than the "de minimis amount," the OID is treated as zero and no holder is required to include such discount in income on a current basis under the OID provisions of Sections 1271 through 1275 of the Code
All three conditions must be satisfied for an obligation to be classified as an AHYDO
An obligation must satisfy all three conditions to be classified as an AHYDO, and the failure of any one condition is dispositive
50% per annum on the principal amount of the Notes; and • The maximum rate of additional interest shall not exceed 1