Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / sc-tax-opinion.docx
sc-tax-opinion.docx
Parties
HARKNESS LLP
Ironhaven Data Centers LLC
US Federal Inc
Ironhaven Frankfurt GmbH
Ironhaven Holdings Inc
Pinnacle Trust Company GmbH
US-Germany Inc
Dixie Dairies Corp
Dates
June 3, 2024
May 15, 2024
June 3, 2031
February 28, 2024
March 31, 2024
March 15, 2024
June 1, 2006
January 1, 2026
December 31, 2025
December 3, 2024
Amounts
$950,000,000
$675,000,000
€253,571,429
$275,000,000
$945,250,000
$14,250,000
$165.8
$950.0
$100.0
$62.5
Obligations
Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Credit Agreement
However, the de minimis calculation must be measured using the "weighted average maturity" of the debt instrument, not simply the stated maturity
03 of the Credit Agreement, which provides that the Administrative Agent shall maintain a register of the names and addresses of the Lenders, the commitments, and the principal and interest owing to each Lender
Article 11(1) of the US-Germany Treaty provides that interest arising in one Contracting State and paid to a resident of the other Contracting State who is the beneficial owner thereof shall be taxable only in the Contracting State of which the beneficial owner is a resident
In other words, interest arising in the United States and paid to a resident of Germany who is the beneficial owner of such interest shall be exempt from US withholding tax — the treaty provides for a 0% rate of withholding on interest, subject to certain conditions
1441-6, the withholding agent (here, the Administrative Agent) must have received a valid IRS Form W-8BEN-E from NordBrücke AG in order to apply the reduced treaty rate