Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-memo-section-731c-marketable-securities.docx
tax-memo-section-731c-marketable-securities.docx
Parties
Solara Consolidated Master Fund LP
Consolidated Master Fund LP
The Consolidated Master Fund LP
Reorganization Solara Digital Infrastructure LP
Solara Digital Infrastructure LP
Final LP
Solara Offshore GP Ltd
Harborstone Corporate Services Ltd
Dates
June 16, 2025
December 1, 2025
March 31, 2025
May 4, 2025
March 14, 2025
April 22, 2025
September 15, 2025
Amounts
$1.72
$14.7
$3.8
$1.85
€1.15
$1.24
1.08 EUR
$2.45
€1.38
$1.49
Obligations
Several of Solara's largest limited partners, including the Nordhaven Sovereign Wealth Fund and the Pinnacle State Employees' Retirement System, have requested that Solara simplify the fund governance structure to reduce the number of advisory committee seats, consent rights, and reporting streams that LPs must monitor across multiple parallel vehicles
Section 731(c)(1)(A) provides, in relevant part: "For purposes of subsections (a)(1) and (b), and for purposes of section 737— (A) the term 'money' includes the fair market value of any marketable security, and (B) such value shall be determined as of the date of the distribution
" However, the financial instrument must be "actively traded" within the meaning of § 1092(d)(1) in order to qualify as a marketable security under this subparagraph