Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / memo-firpta-withholding-analysis.docx
memo-firpta-withholding-analysis.docx
Parties
Harkness LLP
Ridgeline Wireless Holdings LLC
Northgate Wireless Americas Inc
Northgate Telecommunications PLC
Nevada LLC
Northgate US Holdings LLC
Delaware LLC
Wales PLC
Dates
September 26, 2022
September 22, 2022
August 22, 2022
August 30, 2022
September 30, 2022
October 14, 2022
September 12, 2022
February 16, 2016
July 24, 2001
Amounts
$126,500,000
$0.845
$4,500,000
$18,975,000
$1,012,000
$122,000,000
Obligations
Section 1445(a) imposes a withholding obligation on the transferee of a USRPI: the transferee must deduct and withhold a tax equal to 15% of the "amount realized" on the disposition if the transferor is a "foreign person
The withheld amount must be remitted to the IRS within 20 days after the date of the transfer, using IRS Forms 8288 (U
Under the general rule of Section 1445(a), the transferee of a USRPI must withhold 15% of the "amount realized" by the foreign transferor on the disposition