FR EA

Extract to table

Pull the structured facts out of a document: parties, dates, amounts, obligations.

Extract to table / functional-analysis-memo-hsi.docx
functional-analysis-memo-hsi.docx · 1032-00006

Parties

Harkness LLP
Halcyon Semiconductor Inc
Gresham Whitfield LLP
Stonebridge Valuation Partners LLC
Meridian Economics GmbH
Capitol Registered Agents LLC

Dates

December 31, 2024
January 1, 2025
December 31, 2029
January 1, 2022
March 12, 2025
March 13, 2025
March 26, 2025
April 9, 2025
March 18, 2025
April 2, 2025

Amounts

€987,600,000
$1,076,000,000
2024 EUR
€68,400,000
$70,500,000
€224,600,000
$231,300,000
€1,280,600,000
$4,120,000,000
€1,420,000,000

Obligations

This functional analysis is a foundational component of both the bilateral advance pricing agreement ("APA") application that HSI and HSAG intend to file with the Internal Revenue Service ("IRS") and the Bundeszentralamt für Steuern ("BZSt") and the contemporaneous transfer pricing documentation that HSI is required to maintain under applicable US tax law
HSI's account managers and sales engineers may propose pricing within established bands, but deviations from approved pricing guidelines, volume discount structures, and long-term contract terms must be approved by HSAG's global sales leadership
from 7nm to 5nm to 3nm), older-node products may experience declining demand and price erosion, potentially resulting in excess inventory that must be written down or disposed of at a loss