CLO Investments: Navigating Tax Challenges in a Resurging Market
Balancing Between Debt and Equity Tranches; Applying FATCA, PFIC, CFC and NII Regulations; Handling Acquisition Indebtedness
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel and advisors with legal strategies to handle tax issues involved in collateralized loan obligations (CLOs). The panel will offer their insights and perspectives on the differences between debt and equity tranches, application of new FATCA and PFIC regulations, acquisition indebtedness, and more.
- Tax differences between debt and equity tranches
- PFIC and CFC regulations
- FATCA regulations
- Acquisition indebtedness
- Application of NII
- Blocker entities
The panel will review these and other key issues:
- What are the new requirements for FATCA and PFIC compliance? How must counsel best overcome special hurdles for existing CLOs?
- How does the Net Investment Income tax apply to CLOs? What planning strategies must be implemented?
- What are the differences between debt and equity tranches? What considerations must be made in structuring investments in CLOs?
Milbank Tweed Hadley & McCloy
Ms. Rahimi-Laridjani’s practice focuses on the taxation of complex financing transactions, financial products and... | Read More
Ms. Rahimi-Laridjani’s practice focuses on the taxation of complex financing transactions, financial products and derivatives, US and foreign securities offerings, structured finance and investment funds. She has significant experience structuring tax efficient solutions that facilitate inbound investment by funds and foreign and sovereign investors in a variety of asset classes as well as cross-border mergers and acquisitions.Close
Mr. Stein advises on corporate, partnership, and international tax issues. He has represented buyers and sellers in... | Read More
Mr. Stein advises on corporate, partnership, and international tax issues. He has represented buyers and sellers in mergers and acquisitions, investment fund sponsors and institutional investors with respect to investment fund formation, and financial institutions with respect to securities offerings, financings, and financial instruments.Close