Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / pre-submission-conference-agenda-talking-points.docx
pre-submission-conference-agenda-talking-points.docx
Parties
Solara Digital Infrastructure LP
Harkness LLP
Solara Digital Infrastructure GP LLC
Taxpayer Solara Digital Infrastructure LP
Fund IV LP
Consolidated Master Fund GP LLC
Solara Consolidated Master Fund LP
Consolidated Master Fund LP
Dates
July 18, 2025
July 22, 2025
June 27, 2025
July 3, 2025
March 17, 2014
March 31, 2025
December 1, 2025
September 15, 2025
October 1, 2025
October 15, 2025
Amounts
$14.7
$2.31
$1.62
$690
€1.07
$1.16
1.08 EUR
€782
$844.6
€288
Obligations
Section 367(a) provides that, in the case of any exchange described in § 332, § 351, § 354, § 355, § 356, or § 361, if a United States person transfers property to a foreign corporation, such foreign corporation shall not be considered a corporation for purposes of determining the extent to which gain shall be recognized on such transfer
Section 367(b) provides that, in the case of any exchange described in § 332, § 351, § 354, § 355, § 356, or § 361 in connection with which there is no transfer of property described in § 367(a)(1), an amount shall be included in the income of certain United States persons under regulations prescribed by the Secretary
Under that provision, no loss shall be recognized to a distributee partner on a liquidating distribution unless the partner receives only money, unrealized receivables, and inventory