Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / draft-irs-form-8594.xlsx
draft-irs-form-8594.xlsx
Parties
Harkness LLP
Ardent Healthcare Acquisition Corp
Creighton LLP
Ardent Capital Management LLC
Horizon Commercial Lending Corp
Great Plains Capital Partners LLC
Ardent Capital Partners III LP
Growth Equity Fund II LP
Dates
September 28, 2024
June 30, 2024
April 2, 2024
June 30, 2025
June 30, 2026
December 30, 2025
March 15, 2018
June 26, 2024
June 28, 2024
June 30, 2027
Amounts
$620,000,000
$45,000,000
$1,200,000
$29,200,000
$28,000,000
$38,500,000
$2,800,000
$195,700,000
$24,200,000
$18,500,000
Obligations
— Roberta Chen, CPA Buyer's Accounting Advisor (for reference) | Ashford & Creighton LLP — Gregory Nolan, CPA Distribution | Beatrice Holloway (C&H), Derek Okonkwo (C&H), Priya Mehta-Sullivan (Ardent Capital Management LLC), Connor Briggs (Ardent Capital Management LLC) Note | Both Buyer and Seller must file Form 8594 with their respective federal income tax returns for the tax year that includes June 30, 2024
Allocation must be consistent between parties per IRC § 1060 and Treasury Reg
Each tranche payment constitutes additional purchase price under IRC § 1060 and must be allocated using the residual method in a supplemental Form 8594 filing for the year in which payment occurs
A supplemental Form 8594 must be filed by both Buyer and Seller for the taxable year in which payment occurs
4 | Seller Agreement on Allocation | Pending | Barrow, Kensington & Pratt LLP (Catherine Barrow / Samuel Otieno) | Prior to filing | Buyer and Seller must agree on allocation per APA Section [●]
8 | Filing Deadline | Open | Calderwood & Harkness LLP (Sylvia Hartwell) | With 2024 tax returns | Form 8594 must be attached to both Buyer's and Seller's federal income tax returns for the taxable year including the acquisition date (June 30, 2024)