Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-analysis-memorandum.docx
tax-analysis-memorandum.docx
Parties
HARKNESS LLP
Federal Deposit Insurance Corp
Archer Bond Analytics LLC
Redstone Capital Markets LLC
Kensington Hale Securities Inc
Dates
February 10, 2026
February 24, 2026
February 19, 2026
December 31, 2025
September 30, 2025
February 7, 2026
March 1, 2036
September 1, 2026
March 1, 2031
June 1, 2031
Amounts
$350,000,000
$875,000
$8,750,000
$62.4
$349,125,000
$200,000,000
$150,000
$1,000
$2,275,000
$346,850,000
Obligations
Statutory Framework Section 163(a) of the Code provides that "[t]here shall be allowed as a deduction all interest paid or accrued within the taxable year on indebtedness
The Notes must be repaid on the stated maturity date (subject only to the regulatory constraints described above applicable to all bank obligations)
20(d), subordinated debt must have an original maturity of at least five years to qualify as Tier 2 capital
The Notes are not perpetual obligations; they have a definite end date on which the principal must be returned to holders
All three conditions must be satisfied for an instrument to be classified as an AHYDO