Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-planning-memorandum.docx
tax-planning-memorandum.docx
Parties
Harkness LLP
Pellegrino Capital Group LLC
Meridian Shores Hospitality LLC
Costa Luma Resort Holdings LLC
Azulia Beach Club LLC
Callahan LLP
M. Pellegrino
Lindquist LLP
Dates
September 25, 2025
December 15, 2025
December 31, 2024
November 10, 2025
October 20, 2025
October 6, 2025
November 3, 2025
December 15, 2034
December 1, 2025
April 15, 2026
Amounts
$2,000,000
$40,000,000
$285,000,000
$215,000,000
$3,200,000
$2,640,000
$1,300,000
$50,000,000
$22,400,000
$18,500,000
Obligations
The steps must be executed in the order presented to ensure that the Trust has economic substance and independent equity prior to the installment sale
The Seed Gift must be reported on Salvatore's 2025 Form 709 (United States Gift (and Generation-Skipping Transfer) Tax Return), as discussed in Section X of this memorandum
The sale price is, and must be, supported by a qualified appraisal prepared by an independent, qualified appraiser
• Prepayment: The Trust shall have the right to prepay the Note, in whole or in part, at any time without premium or penalty
40%, the interest rate on the Note must be adjusted upward to at least the December 2025 rate
Following the transfer, the Trust will hold the same percentage interests as Salvatore currently holds, but the Trust's interests are held by an independent trustee who must act in a fiduciary capacity and whose authority is governed by the trust instrument and applicable law rather than by entrepreneurial discretion