Extract to table

34 billion • Total portfolio companies: 23 (11 held by Fund IV vehicles; 12 held by Fund V vehicles) The FMV determinations are critical for multiple provisions of the Internal Revenue Code ("Code" or "IRC"), including: (i) the IRC § 721(a) contribution analysis and the associated nonrecognition treatment; (ii) the IRC § 704(c) built-in gain and loss account tracking that must be maintained by the Consolidated Master Fund using the remedial allocation method; (iii) the IRC § 752 liability allocation modeling for the $1

FMV at the time of each contribution to the Consolidated Master Fund establishes the built-in gain or loss accounts that must be maintained and tracked under IRC § 704(c) for each contributed property

03 billion aggregate adjusted tax basis) must be precisely allocated across all 23 portfolio companies and tracked on a property-by-property basis

Because Crestline is a disregarded entity owned by a Luxembourg SCSp, the contribution in the Reorganization involves the underlying assets of the LLC flowing through, and the valuation must be conducted at the enterprise level

In the context of the Reorganization, the FMV standard must be applied to the partnership interests and portfolio company equity interests being contributed under Subchapter K of the Code

For purposes of the PLR submission, FMV must be determined as of the specific contribution dates for each Step of the Reorganization