Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-section-731-distribution-analysis.docx
tax-memo-section-731-distribution-analysis.docx
Parties
Harkness LLP
Solara Digital Infrastructure LP
Solara Consolidated Master Fund LP
Consolidated Master Fund LP
Platform Solara Digital Infrastructure LP
Solara Digital Infrastructure GP LLC
Harborstone Corporate Services Ltd
Solara Offshore GP Ltd
Dates
June 16, 2025
December 1, 2025
August 15, 2025
March 31, 2025
March 17, 2014
September 15, 2025
October 1, 2025
October 15, 2025
November 1, 2025
April 22, 2025
Amounts
$14.7
$1.85
€1.15
$1.24
1.08 EUR
$2.45
€1.38
$1.49
$2.31
$1.62
Obligations
Under IRC § 731(b), no gain or loss shall be recognized to a partnership on a distribution to a partner of property, including money
Section 731(b) — No Gain or Loss to Distributing Partnership IRC § 731(b) provides a simple and absolute rule: no gain or loss shall be recognized to a partnership on a distribution to a partner of property, including money
Overview of the § 752 Issue The dissolution of the Legacy Offshore Vehicles in Step 5 creates a potential § 752 issue that must be analyzed in conjunction with the § 731 distribution analysis