FR EA

Extract to table

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

Extract to table / tax-structure-memorandum.docx
tax-structure-memorandum.docx · 1036-00004

Parties

HARKNESS LLP
Greystone Meridian Capital LLC
Veltrano Capital Lending Corp
Ashford Prewitt LLP
Blackridge Hayes LLP
Oakes LLP
Target Entity LLC
The LLC

Dates

July 1, 2028
March 1, 2029
December 1, 2030
December 31, 2023
September 15, 2020
February 1, 2021
November 22, 2019
October 18, 2023

Amounts

$4.8
$1,100,000,000
$2.4
$612,000,000
$421,600,000
$142,300,000
$48,100,000
$488,000,000
$750,000,000
$74,800,000

Obligations

an acquisition of a trade or business in which the purchaser's basis in the acquired assets is determined by reference to the consideration paid), the purchase price must be allocated among the acquired assets using the residual method prescribed in Treasury Regulations Section 1
Draft IRS Form 8594 (Asset Acquisition Statement Under Section 1060) must be prepared and filed by both the Buyer and the Seller with their respective federal income tax returns for the taxable year in which the acquisition occurs
At the close of each calendar quarter, at least 75% of the value of a REIT's total assets must consist of real estate assets (as defined in Section 856(c)(5)(B)), cash and cash items (including receivables), and government securities
For this rental income to qualify under the 75% gross income test, it must constitute "rents from real property" as defined in Section 856(d) of the Code
Services provided by Fairwater Property Management LLC (such as maintenance, repair, landscaping, janitorial, and security services) must be "customarily furnished or rendered" in connection with the rental of logistics, industrial, and office properties in the relevant Sun Belt markets
The increased rental income will require corresponding increased distributions, which must be reflected in Fairwater's dividend planning for the taxable year of acquisition and subsequent years