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Memory

Agentic Memory built on
multi-year client decisions

Tax is the one profession where last year is the answer. Pernee keeps why a position was taken, who signed it and what it was questioned on — and brings it back the season it matters.

Why did we make the Section 754 election for Ridgeline in 2024, and who signed off on how the step-up was allocated?

Firm memoryRecalled 5 items · 9s

The firm made the election because Harbor Point LP bought a 12% Class A interest from Aldine Partners for $4.1M more than its share of inside basis. Without it, Harbor Point would be taxed on gain it had already paid for.14

A. Morgan signed the position memo on February 18, 2025. Her review asked for the Section 743(b) step-up to be allocated to the portfolio investments under the residual method, not to goodwill at the fund level.12

Mark Ellison questioned the election in March because it cannot be revoked. The team kept it after showing that two more transfers were expected in 2025.3

Both transfers closed. The 2025 return needs a new Section 743(b) adjustment for each, and the 2024 election already covers them.5

Not found in your sources. No record of who approved the Harbor Point side letter terms.

Memory · Ridgeline

  1. 1Position memo · Section 754 election 2024Position · signed by A. Morgan · Feb 18, 2025
  2. 2Review notes 2024 · A. MorganReview · 5 notes
  3. 3Email · Mark Ellison, CFOCorrespondence · Mar 12, 2025
  4. 42024 Form 1065 · Statement 3Vault · as filed
  5. 5Partner transfer log 2025Vault · Source documents

Remember every decision
across every tax year

Capture

Picks up positions, review notes and client answers from the work as it happens. Nobody writes anything down twice.

Connect

Links each decision to the client, the entity, the year and the person who made it, so the reasoning stays attached to the return.

Recall

Brings the right precedent back when a similar question comes up, with the source it came from.

Update

When a position changes, the old one is marked superseded, not deleted. You can always see what the firm believed and when.

Your firm's reasoning lives in 40 inboxes

hrs / person / week

Spent looking for files across email, SharePoint and Drive.

An engagement changes hands, shedding context each time.

The same numbers get re-keyed before anything is final.

Facts that belong to the client,
not to a return.

Elections

Made once, carried every season, with who made them.

Carryforwards

NOLs, credits and basis, with the workpaper they came from.

Methods

Accounting methods and the year they were adopted.

Positions

The authority relied on and the reviewer who signed it.

Open questions

What was never resolved, marked as such.

Provenance

Nothing enters the register without a source.

Every position remembered
with who decided and why

Memory· Ridgeline Capital · Section 743(b) step-up3 tax years · 24 positions
2023Return filed Sep 2024
No Section 754 election. One partner transfer below threshold.Review notes · J. Okafor
Section 704(c) layer created for the Harbor Point building contribution.Contribution memo · $1.91MStill current
2024Return filed Sep 2025
Allocate the step-up to fund-level goodwill.Draft · Jan 2025Superseded Feb 2025
Elect Section 754. Allocate the step-up to portfolio investments under the residual method.Position memo · signed by A. MorganCurrent
CFO questioned the election because it cannot be revoked. Kept after two transfers were confirmed.Email · Mark Ellison · Mar 2025
2025In preparation
Recalled from 2024
Two Class A transfers closed in May and October. Each needs its own Section 743(b) adjustment under the 2024 election.Partner transfer log 2025
Harbor Point side letter terms.No approval found in memoryAsk A. Morgan

FAQs

The review comments on each line of the return, the positions and elections taken, and who signed off on them. Each is stored with the document it came from.

From the prior-year returns, workpapers and review notes already in the firm's folders. Nobody has to re-enter them.

Yes. Every carried comment shows the original line, the reviewer, the date and the source file.

Yes. A reviewer can edit or retire any item, and the change is recorded against it.

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