Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-entity-classification-7701.docx
tax-memo-entity-classification-7701.docx
Parties
Solara Consolidated Master Fund LP
Harkness LLP
Solara Digital Infrastructure LP
The Master Fund LP
Master Fund LP
Context Solara Digital Infrastructure LP
Formal LP
Consolidated Master Fund GP LLC
Dates
June 16, 2025
September 15, 2025
March 17, 2014
March 31, 2025
March 14, 2025
April 22, 2025
December 1, 2025
October 1, 2025
October 15, 2025
November 1, 2025
Amounts
$14.7
$3.8
$2.31
$1.62
$690
$1.16
$844.6
$311
$2.89
$2.34
Obligations
As a threshold matter, the entity must constitute a "business entity" within the meaning of Treas
The election is made by the entity itself, and must be signed by an authorized person
A copy of the Form 8832 must be attached to the entity's federal tax return (e
The formation of the International Feeder under Cayman law must be completed before or simultaneously with the filing of the Form 8832 election
The Tax-Exempt Feeder must be a pass-through entity for U
person who transfers property to a foreign corporation in a transaction described in § 332, § 351, § 354, § 356, or § 361 must recognize gain on the transfer as if the property had been sold at fair market value