Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / structuring-memo-tax-and-structural-issues.docx
structuring-memo-tax-and-structural-issues.docx
Parties
HARKNESS LLP
Driftwood Absolute Return Fund Ltd
Driftwood Credit Management LLC
National Registered Agents Inc
Brindoval Analytical Services Inc
Ridgeline Credit Ratings LLC
Federal Inc
Greystone Audit Partners LLP
Dates
May 18, 2023
May 22, 2023
May 15, 2023
January 15, 2024
September 12, 2025
September 12, 2028
October 15, 2036
December 12, 2023
June 1, 2023
August 18, 2023
Amounts
$6.8
$400,000,000
$250,000,000
$364,000,000
$36,000,000
$250,000
$1,000
$600,000
$150,000
$1,400,000
Obligations
Interest and principal payments on the notes will be made quarterly on each Payment Date, which shall be the 15th day of January, April, July, and October of each year, commencing January 15, 2024
The record date for each Payment Date shall be the 15th calendar day preceding such Payment Date
The reinvestment period shall be five years from the Closing Date, expected to end on September 12, 2028
No Form 8832 is required to be filed for the Co-Issuer unless the parties wish to affirmatively elect away from the default classification, which we do not recommend
The rated notes have a stated maturity date of October 15, 2036, by which all principal must be repaid
Conversely, if the subordinated notes are treated as equity, holdings of subordinated notes by benefit plan investors must be monitored to ensure that the 25% threshold is not breached