Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / new-matter-opening-memorandum.docx
new-matter-opening-memorandum.docx
Parties
HARKNESS LLP
Harrowgate Capital Advisors LLC
Crowne Albany Corp
Capital Partners IV GP LLC
Counsel Harrowgate Capital Advisors LLC
Officer Harrowgate Capital Advisors LLC
Operations Harrowgate Capital Advisors LLC
Distributing Corp
Dates
March 14, 2019
June 7, 2019
February 12, 2003
September 20, 2019
April 11, 2022
April 18, 2022
April 25, 2022
Amounts
$6.8
$2.34
$418
$1.52
$285
$820
$133
$295
$1,859,520,000
$40.00
Obligations
§ 355(e) Anti-Morris Trust — Plan Analysis IRC § 355(e) provides that if a distribution otherwise qualifying under § 355(a) is part of a "plan (or series of related transactions)" pursuant to which one or more persons acquire, directly or indirectly, stock representing a 50-percent or greater interest in the distributing corporation or any controlled corporation, the distributing corporation must recognize gain on the distribution as if it had sold the controlled corporation's stock for its fair market value
The engagement team is reminded that any new parties or entities identified during the course of the engagement must be promptly submitted for supplemental conflicts screening in accordance with firm policy