FR EA

Extract to table

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

Extract to table / state-income-franchise-tax-memorandum.docx
state-income-franchise-tax-memorandum.docx · 1036-00004

Parties

Harkness LLP
Ashford Prewitt LLP
State Inc
Delaware LLC
Delaware-formed LLC
Greystone Meridian Capital LLC
Oakes LLP
GMP Fairfield II LLC

Dates

May 17, 2024
March 22, 2024
June 6, 2024
January 1, 2024
June 5, 2024
December 31, 2024
April 15, 2025
October 15, 2025
April 1, 2025
May 15, 2025

Amounts

$1,100,000,000
$10
$10,000
$5,000
$22,000,000
$50
$20
$138.75
$100
$1.50

Obligations

Each state's treatment of REITs varies, and the availability of a state-level dividends-paid deduction (or equivalent mechanism) must be analyzed on a jurisdiction-by-jurisdiction basis
Delaware LLCs that are qualified to do business in Georgia as foreign limited liability companies must file annual registrations with the Georgia Secretary of State pursuant to O
These registrations must be maintained on an ongoing basis, and the annual registration fee is approximately $50 per entity
However, the Comptroller has taken the position that a disregarded entity that itself has nexus with Texas must ensure that its owner (the taxable entity) includes the disregarded entity's Texas-source revenue in its Texas franchise tax report
Accordingly, Fairwater REIT, as the sole member of the three Texas Target Entities, must include the revenue generated by GMP Westlake LLC, GMP Katy LLC, and GMP Alliance LLC in its Texas franchise tax report
Each entity that files a Texas franchise tax report must concurrently file a Public Information Report ("PIR") with the Texas Comptroller of Public Accounts