Understanding Tax Receivable Agreements

The passage of the tax reform last December gave investors greater security when it comes to corporate tax rates in the near future. One of the consequences is an increased interest on the part of some investors in the acquisition of payment rights under so-called “tax receivables” (“TRAs”) agreements. In short, TRAS are agreements entered into by a company (a “Pubco”) as part of an initial public offering (“IPO”) to monetize the tax characteristics of the post-IPO pubco for the benefit of pre-IPO owners and investors who acquire payment rights under TRAs from these pre-IPO owners. Our previous article on TSEs focused on some of the ways in which tax reform could affect the value of AER`s payment entitlements. Since the adoption of the tax reform, we have seen a significant increase in investor interest in acquiring tra payment rights, in particular hedge funds, family offices and private investment funds. This article describes some of the characteristics of an TRA that an investor should analyze before acquiring rights under an TRA. The lawyer should have a thorough understanding of the legal, tax and economic impact of CATs before including them in an IPO or M&A transaction. The speakers were very well informed and well informed. Mr. Marcellino is co-director of the company`s Mergers and Acquisitions group and works in the New York office. That`s him. | Read More Strafford`s live webinars offer you a high-quality, inexpensive and convenient CLE option, with no waste of travel time or cost. See CLE State Map >> M.

Marcellino is co-director of the company`s Mergers and Acquisitions group and is headquartered in the New York office. He has a wide range of transaction practices and represents a mix of clients of corporate public and private investment funds and private equity investment funds in a number of transactions of global importance. Specifically, Mr. Marcellino has led representations on mergers and acquisitions, capital buybacks, leverage levers, preferred equity investments, PIPE investments, as well as various securities offerings and compliance and governance issues. He has represented and represents some of the most outstanding private equity firms in the global market, including TPG Capital, H.I.G. Capital, JMI Equity and Welsh, Carson, Anderson & Stowe, as well as their holding companies. The two most common forms of TRAs are “NOL TRAs” and “Step-Up TRAs”: On-demand webinars are available 48 hours after the live program and include video streaming of the entire program as well as handouts. They are accessible 24 hours a day, 7 days a week. You can listen to the whole program during a session or pause and return to where you left off. Strafford offers continuous access for one year to all on-demand programs you purchase.

I liked that Strafford`s program covered real-life situations and claims. Mr. Greenwood is a partner in the tax and benefits department. Its activities focus on transaction tax issues, including private equity, real estate and hedge fund issues; mergers and acquisitions; inbound and outbound investment; and secondary transactions. Strafford`s webinars are backed by our 100% unconditional money back guarantee: If you`re not satisfied with any of our products, just let us know and get a full refund…

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