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 · 1038-00009

Parties

HARKNESS LLP
Cascade Retail Holdings Inc
SVP Corp
Paige LLP
NovaMart Global Inc
The Nasdaq Stock Market LLC
Loewe LLP
Pennington Advisory Group LLC

Dates

May 18, 2025
May 20, 2025
December 31, 2024
May 19, 2025
October 15, 2025
February 3, 2025
February 14, 2025
December 31, 2017
December 31, 2021

Amounts

$1,200,000,000
$95
$55
$96,000,000
$1,104,000,000
$750,000,000
$200,000,000
$250,000,000
$14.7
$1.83

Obligations

Legal fees incurred for negotiation and drafting of the SPA, ancillary transaction documents, and closing activities are facilitative costs that must be capitalized into Cascade's basis in the NovaMart stock under Treas
as financial advisor is a facilitative cost of the acquisition and must be capitalized into Cascade's basis in the NovaMart stock
As with legal fees, accounting and tax advisory fees attributable to the investigatory or evaluative phase may be currently deductible, while fees attributable to facilitating the transaction must be capitalized
263(a)-5, this cost must be capitalized into Cascade's stock basis
The Hart-Scott-Rodino Act filing fee is a cost directly attributable to the acquisition and must be capitalized into Cascade's stock basis under Treas
The combined incremental debt of $950,000,000 will generate significant annual interest expense that must be evaluated under the Section 163(j) business interest expense limitation