Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / internal-comments-draft-opinion.docx
internal-comments-draft-opinion.docx
Parties
HARKNESS LLP
Harrowgate Capital Advisors LLC
Gage LLP
Prescott Capital Management LP
Associates LLC
Pemberton Rathbone LLP
Harrowgate Veldran Holdings LLC
Distributing Corp
Dates
August 10, 2022
August 5, 2022
July 11, 2022
July 20, 2022
September 20, 2019
June 10, 2022
July 8, 2022
July 22, 2022
August 15, 2022
June 7, 2019
Amounts
$40.00
$1,859,520,000
$1,396.5
$1,702.4
$133
$800
$596.5
$902.4
$125.3
$189.5
Obligations
THIS DOCUMENT SHALL NOT BE DISCLOSED TO ANY CLIENT, CO-COUNSEL, OPPOSING PARTY, OR ANY THIRD PARTY WITHOUT THE EXPRESS WRITTEN AUTHORIZATION OF THE RESPONSIBLE PARTNER
Cross further flags that the draft must include a more prominent caveat regarding the Representation Letter
This is inadequate for an opinion of this significance and must be rectified
The revised draft must include an explicit discussion of the safe harbor provided under Treasury Regulations Section 1
The opinion must squarely address this condition and state the basis for concluding that it is met
The revised draft must also discuss the facts-and-circumstances test set forth in Treasury Regulations Section 1