As a result of the transaction approximately 430 employees globally, including Newmarket's entire management team, will become part of the Amadeus Global Hotel Group, maintaining Newmarket's headquarters location in Portsmouth, New Hampshire.
Under the first
of those agreements, we generally will be required to pay to our existing owners that will continue to hold LLC Units following the reorganization
transactions approximately 85 %
of the applicable savings, if any, in income tax that we are deemed to realize (using the actual applicable U.S. federal income tax rate and an assumed combined state and local income tax rate)
as a
result of:
Upon closing
of this offering, we will record $ million
as an increase to the liabilities due to existing owners under certain
of the TRAs, see «Notes to Unaudited Pro Forma Consolidated Balance Sheets,» and in the future we may record additional amounts
as additional liabilities due to existing owners under the five TRAs, such amounts collectively representing our estimate
of our requirement to pay
approximately 85 %
of the estimated realizable tax benefit
resulting from (i) any existing tax attributes associated with interests in Desert Newco, LLC acquired in the Reorganization
Transactions and the exchanges described above, the benefit
of which is allocable to us
as a
result of the same, (ii) the increase in the tax basis
of tangible and intangible assets
of Desert Newco, LLC
resulting from the exchanges
as described above and (iii) certain other tax benefits related to entering into the TRAs, including tax benefits related to imputed interest and tax benefits attributable to payments under the
As a
result of the deal, the Simon portfolio grew to 241 retail properties in 35 states comprising a total GLA
of 165 million sq. ft.. The
transaction valued CPI at
approximately $ 5.78 billion, including the assumption
of debt.