Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-post-closing-integration.docx
tax-memo-post-closing-integration.docx
Parties
HARKNESS LLP
Delaware General Corp
Stratos Merger Sub Inc
Digital Infrastructure Fund VI LP
Cloudium Inc
Cloudium Technologies UK Ltd
Cloudium Solutions GmbH
Glenmore Thornton LLP
Dates
July 9, 2024
July 9, 2031
November 1, 2023
December 12, 2023
June 15, 2024
June 20, 2024
September 30, 2023
December 10, 2023
Amounts
$6,800,000,000
$36.92
$405,000,000
$3,740,000,000
$500,000,000
$142,814,544
$473,241,408
$425,000,000
$390,000,000
$1.25
Obligations
The feasibility of this approach must be confirmed with UK solicitors
Hargrove and Pinnacle Growth Ventures LLC) must be carefully analyzed to ensure that the transaction does not trigger taxable gain recognition at the rollover equity level
However, the applicability of the SSE to each subsidiary must be individually confirmed, and the SSE does not apply to gains on assets other than shares in qualifying subsidiaries (e
We note at the outset that the decision to migrate IP from the UK to the US involves significant trade-offs that must be carefully evaluated
The cost/benefit analysis must be rigorously quantified before any migration is executed
An arm's-length transfer price must be established for the IP assets being migrated