Financial products in United States
All lawyers mentioned in this section are based in New York City, unless mentioned otherwise.
The tax team at Cadwalader, Wickersham & Taft LLP handles a range of mandates involving structured and leveraged finance deals, as well as securitizations. Gary Silverstein and the Washington DC-based Jason Schwartz are key contacts for tax matters relating to CLOs, and Linda Swartz heads the firm's broader tax group. Prestigious institutional clients include ISDA and the Federal Reserve's Alternative Reference Rates Committee.
PennyMac Mortgage Investment Trust
Waterfall Asset Management
- Advising Bank of America on a $950m CMBS loan securitization, which was cross-defaulted and cross-collateralized with a subordinate loan backing taxable bonds issued by New York Liberty Development Corporation.
- Advised MBIA on two CLO funds known as Zohar I and Zohar II, which were subject to Delaware insolvency proceedings.
Cleary Gottlieb Steen & Hamilton
Cleary Gottlieb Steen & Hamilton's multi-disciplinary practice group advises on a range of complex tax issues, including those arising from securitizations and capital markets transactions. Corey Goodman and Jason Factor are key names in tax team. Erika Nijenhuis left for a senior in-house role at the Office of Tax Policy in September 2019.
- Advised various investment banks on over 200 of Fannie Mae, Freddie Mac and Ginnie Mae’s REMIC transactions totaling $117bn.
- Advised BNP Paribas on purchasing Deutsche Bank’s Delta One hedged derivatives book.
- Advised TPG on the formation of its $11.5bn TPG Partners VIII fund.
Clifford Chance's 'one-stop shop' tax practice acts for a number of banks and elite asset managers covering real estate and debt, and routinely handles cross-border mandates in conjunction with its London office. Names to note include David Moldenhauer, rated for his 'excellent knowledge' of CLO taxation; James Gouwar, who has particular expertise in the tax aspects of securitizations; and Michael Seaton, who is noted for his experience of tax matters in the areas of insurance, real estate and private equity.
‘One stop shop managing all aspects.’
‘David Moldenhauer has excellent knowledge.’
Apollo Commercial Real Estate Finance
Oak Street Real Estate Capital
Global Jet Capital
Bayview Asset Management
- Advised Watford Holdings on the issuance of $175m of unsecured notes, considered Tier 3 capital by the Bermuda Monetary Authority.
- Advised Business Jet Securities on the tax aspects of several note issuances.
- Advised an affiliate of IFG on a $125m revolving, asset-backed loan to FastPay Capital, arranged without the involvement of investment banks.
- Advised Bayview Asset Management on the tax elements of several US government agency credit risk transfers.
- Advised National Storage Affiliates on the sale of shares using a forward sale agreement.
Davis Polk & Wardwell LLP
At Davis Polk & Wardwell LLP, Michael Farber, Lucy Farr and Po Sit advise on the tax aspects of major financial institutions on structured finance offerings, and work related to funds and commodities. Also recommended is Michael Mollerus, who has expertise in the tax components of structured notes and telecoms securitization deals. David Schnabel heads the firm's broader tax practice, and Avishai Shachar retired from the partnership and is now in a senior counsel role.
Mayer Brown has 'unusual and exceptional experience relating to tax planning, structured financial transactions and derivatives'. Michael Marion and Russell Nance are particularly strong in CLO taxation, and Steven Garden in Chicago has recently been active in the area of mortgage insurance-linked notes. Remmelt Reigersman in San Francisco is a key contact for securitization work; he frequently works alongside the 'unusually valuable' Thomas Humphreys, who is also a leading academic in the field of taxation. Another name to note is Mark Leeds, who has expertise in the taxation of funds.
Other key lawyers:
‘Mayer Brown has unusual and exceptional experience relating to tax planning, structured financial transactions and derivatives‘.
‘Tom Humphreys’ range and depth of knowledge, both relating to tax and commercial issues, is amazing. He has worked for a wide range of financial institutions, involving an exceptional range of transactions.’
‘Mark Leeds and Remmelt Reigersman also have outstanding experience and knowledge relating to structured finance, derivatives, and financial transactions.‘
HPS Investment Partners
MJX Venture Management
Citigroup Global Markets
Wells Fargo Securities
First State Investments
JP Morgan Securities
Credit Suisse Securities
Natixis Securities Americas
Bank of America Merrill Lynch
National Bank of Canada
Bank of Montreal
Royal Bank of Canada
- Advised HPS Investment Partners on the tax aspects of non risk-retention new CLO issuances and resets.
- Advised MJX Venture Management on the issuance of risk-retention notes, CLO resets and new CLO issuances.
- Advised investment banks include Credit Suisse and BNP Paribas on the issuance of $700m of mortgage insurance-linked notes.
- Acting for Citigroup Global Markets as underwriter of new CLO issuances by, among others, Oaktree Capital Management, KKR, BlackRock Financial Management and Octagon Credit Investors.
- Advised LendingClub Corporation on its securitization of $288m of consumer loans.
At Shearman & Sterling LLP, Kristen Garry - head of the firm's Washington DC office - is a key name for handling work concerning the tax aspects of structured debt, among other matters. Also in the DC office, Nathan Tasso is sought by bank and non-bank clients to advise both on transactional tax matters and tax controversies. Michael Shulman heads the firm's wider tax practice in the New York office. Robert Rudnick has retired from the partnership and moved into an of counsel role.
Oaktree Capital Transportation Infrastructure Fund
NatWest Markets Securities
- Advised ARD Securities Finance SARL on issuing securitized senior notes.
- Advised Liberty Global on a Dutch auction tender offer.
Dentons is well known for its work in the securitization of residential and commercial mortgage loans, and its tax practice is an important component of its ability to handle those mandates. A key contact in the team is Andrea Mandell, an expert in the taxation of mortgage-backed securities, and a trusted advisor to clients such as Credit Suisse. Also recommended is Jon Hutchens, who has expertise in tax work around derivatives.
Andrea Mandell; Jon Hutchens
Credit Suisse Securities (USA)
Wells Fargo Securities
Cantor Fitzgerald & Co
Spire Capital Partners
DLJ Mortgage Capital
Nomura Securities International
PennyMac Mortgage Investment Trust
- Advised the initial purchasers, including Credit Suisse and Wells Fargo, on the tax elements of a securitization of qualified residential mortgages.
- Advised Credit Suisse subsidiaries on the bank’s first securitization of non-qualified mortgages.
- Advised the initial purchasers, including Nomura and Credit Suisse, on a securitization of Deephaven Residential Mortgage Trust 2019-1.
- Advised PennyMac Mortgage Investment Trust on the issuance of notes and certificates secured by credit risk transfer certificates.
Freshfields Bruckhaus Deringer LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP has considerable strengths in securities transactions and financial products. David Rievman and Diana Lopo are key names for advice on the tax aspects of innovative and complex structured capital markets transactions. The team is also a go-to tax counsel for hedge funds. Steven Matays heads the firm's New York tax practice.
- Advised Altbaba on a tender offer of its shares in exchange for Alibaba shares and cash.
- Advised the issuers on the New York IPO of shares in the company which owns Studio City in Macau, which was structured as a “Synthetic Up-C”.
- Advised Och-Ziff Capital Management on numerous matters.
Stroock & Stroock & Lavan LLP
The team at Stroock & Stroock & Lavan LLP acts for a number of real estate investors, elite-level banks, hedge funds, and ad-hoc committees of noteholders, with expertise in transactions involving traditional and more unusual real estate assets. Jeffrey Uffner and Michelle Jewett are names to note for tax work relating to investment funds and REITs. Mayer Greenberg left the firm for Kramer Levin Naftalis & Frankel LLP.
JP Morgan Investment Management
Axar Capital Management
CBS Broadcasting Company