Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / memo-pfic-analysis.docx
memo-pfic-analysis.docx
Parties
Harkness LLP
Material United States Federal Inc
Germany Inc
Halcyon Semiconductor USA Inc
Halcyon Power Solutions GmbH
Whitfield GmbH
Whitfield LLP
Passive Inc
Dates
February 5, 2026
December 31, 2023
December 31, 2024
December 31, 2025
November 20, 2025
January 15, 2026
January 10, 2026
Amounts
$900,000,000
€8.6
€3,214
€12
€10
€3,508
€520
€610
€16
€14
Obligations
Consequences if Halcyon Were Classified as a PFIC Although we have concluded that Halcyon is not a PFIC for FY2023, FY2024, or FY2025, the prospectus must describe the potential consequences that would apply if the Company were classified as a PFIC in any taxable year