Extract to table

However, this conclusion is preliminary and must be confirmed through the E&P diligence described below

This assumption is critical to the analysis and must be confirmed

The characterization waterfall under IRC § 301(c) must be applied in the order specified above

This accumulated E&P must also be reduced by the 2021 dividend recapitalization of $275,000,000 to the extent that distribution was characterized as a dividend (i

This analysis is complex and fact-specific, and the availability and amount of the DRD must be determined separately for each corporate partner

To qualify for the preferential rate, the dividend must be paid by a domestic corporation (Nexford is a domestic corporation) and the shareholder must satisfy a holding period requirement: the shareholder must have held the stock for more than 60 days during the 121-day period beginning 60 days before the ex-dividend date