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Extract to table / section-355d-disqualified-distribution-memo.docx
section-355d-disqualified-distribution-memo.docx
Parties
HARKNESS LLP
Greystone Partners Fund III LP
Harrowgate Capital Advisors LLC
Prescott Capital Management LP
Industrial Partners Fund II LP
Capital Partners IV GP LLC
Harrowgate Veldran Holdings LLC
Omnibus Equity Inc
Dates
July 8, 2022
September 20, 2019
June 28, 2022
June 30, 2022
June 7, 2019
July 11, 2022
July 6, 2022
June 10, 2022
March 14, 2019
December 31, 2021
Amounts
$1,859,520,000
$40.00
$596.5
$902.4
$125.3
$189.5
$2.34
$418
$820
$133
Obligations
The effect of a disqualified distribution is set forth in Section 355(d)(1), which provides that Section 355(c)(2) — the provision that generally permits the distributing corporation to distribute controlled corporation stock without recognizing gain — "shall not apply" to a disqualified distribution
Impact on Distributing Corporation (Veldran) If the Distribution is a "disqualified distribution" under Section 355(d)(2), the consequence under Section 355(d)(1) is that Section 355(c)(2) — the provision that generally permits the distributing corporation to distribute controlled corporation stock without recognizing gain — "shall not apply