Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-gross-up-indemnity-analysis.docx
tax-gross-up-indemnity-analysis.docx
Parties
HARKNESS LLP
Ironhaven Data Centers LLC
Ironhaven Frankfurt GmbH
Ironhaven Holdings Inc
Pacific Rim Institutional Lending Corp
Germany Inc
IHDC Frankfurt GmbH
Percentage Inc
Dates
April 28, 2024
May 15, 2024
May 1, 2024
June 3, 2031
June 3, 2024
April 18, 2024
April 5, 2024
Amounts
$950,000,000
$150,000,000
$75,000,000
$675,000,000
€253,571,429
$275,000,000
$945,250,000
$2,375,000
$1.4286
$1,795,500
Obligations
it is not excluded as an "Excluded Tax"), the Borrower must pay additional amounts to ensure that the relevant Lender receives the full contractual interest payment net of all deductions and withholdings
federal withholding tax is 30% (the statutory rate under IRC § 881(a)) and that the Borrower is required to make a quarterly interest payment of $X to a non-U
In order to ensure that the Lender receives $X after withholding, the Borrower must pay a grossed-up amount of $X / (1 – 0
which must deliver a valid Form W-8BEN-E to claim the portfolio interest exemption
First, the Borrower must make the required deduction or withholding
Second, the Borrower must remit the withheld amount to the appropriate governmental authority