Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / memo-tax-codi-section-108.docx
memo-tax-codi-section-108.docx
Parties
Harkness LLP
Debt Inc
Thalassa Americas Inc
Logistics SA
Dralvecen Mezzanine Capital LLC
Capitol Registered Agents LLC
KFO Holdings SA
Supply SA
Dates
December 12, 2022
September 30, 2022
December 15, 2024
June 15, 2024
December 20, 2022
June 15, 2019
March 1, 2020
March 1, 2025
December 1, 2022
January 1, 2023
Amounts
$112.3
$100
$12.3
$540
$270
$185
$200
$85
$76.4
$60
Obligations
Each of these modifications must be tested independently and in combination to determine whether the aggregate effect constitutes a significant modification
The equity component must be valued at fair market value as of the date of the exchange
The issue price of the new notes must be determined under §§1273 and 1274 of the Code
(ii) 15% Equity in TSL: The fair market value of the 15% equity interest in TSL must be determined as of the exchange date
TSL is the primary obligor on the mezzanine notes, and TAI's role under the credit documents must be examined to determine whether TAI is a co-obligor (jointly and severally liable for the full $112
However, if any portion of the currently drawn $185 million is required to be repaid as a result of the commitment reduction (i