Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-section-721a-contribution-analysis.docx
tax-memo-section-721a-contribution-analysis.docx
Parties
HARKNESS LLP
Solara Digital Infrastructure LP
Solara Consolidated Master Fund LP
Master Fund LP
Redstone Advisory Group LLC
Platform Solara Digital Infrastructure LP
Solara Digital Infrastructure GP LLC
Fund IV LP
Dates
June 16, 2025
August 15, 2025
March 17, 2014
March 31, 2025
June 15, 2021
July 12, 2013
September 30, 2023
September 15, 2025
December 1, 2025
March 14, 2025
Amounts
$7.75
$6.03
$1.72
$14.7
$4.2
$1.85
€1.15
$1.24
1.08 EUR
$5.6
Obligations
The regulation further provides that "Section 721 shall not apply to a transaction between a partnership and a partner not acting in his capacity as a partner