Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-firpta-section-897.docx
tax-memo-firpta-section-897.docx
Parties
Solara Digital Infrastructure LP
Harkness LLP
NovaBright Data Systems Inc
Thorngate Fiber Networks LP
Veridian Edge Computing Corp
Crestline Cloud Solutions LLC
Helix SaaS Holdings Ltd
Master Fund LP
Dates
June 16, 2025
August 15, 2025
December 1, 2025
September 15, 2025
July 22, 2025
March 17, 2014
March 31, 2025
October 1, 2025
October 15, 2025
November 1, 2025
Amounts
$380
$500
€200
€275
$14.7
$4.2
$1.85
€1.15
$1.24
1.08 EUR
Obligations
Under IRC § 1446(f)(1), the transferee of a partnership interest is required to withhold ten percent (10%) of the amount realized on the transfer if any portion of the gain on the transfer would be treated as ECI under IRC § 864(c)(8)
Real Property Analysis: NovaBright's data center operations involve significant physical real property assets that must be analyzed under the USRPI framework