Martin Janoušek

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603 151 065




The passage of tax reform last December gave investors greater security when it comes to corporate tax rates in the near future. One consequence is the increased interest of some investors in acquiring payment rights under existing tax receivable agreements (TRAs). In short, ACCORDS are agreements made by a company (a „pubco“) as part of an IPO to monetize Pubco`s tax attributes after the IPO for the benefit of owners prior to the IPO and investors who acquire payment rights under TRAs to such pre-IPO owners. Our previous article on ARTs focused on some ways in which tax reform could affect the value of TRA payment rights. Since the introduction of tax reform, we have seen a marked increase in investor interest in the acquisition of TRA payment rights, including through hedge funds, family offices and private trust funds. This article describes some of the functions of an AED that an investor should analyze before acquiring rights under an AER. Mr. Greenwood is a partner who works in the Tax and Social Benefits Department. His practice focuses on transaction tax… | Read more. Mark N. Berman Adjunct Professor Northeastern University School of Law Pénalford treat the CLE credit for one person on each record. All formats contain program prospectuses.

To find out which registered format offers the best CLE option, select your state: TRAs typically contain comprehensive assignment provisions that allow TRA holders to sell future claims to external investors. In the short term, tax reform has increased security with respect to corporate tax rates, which has increased the interest of hedge funds and other private investment vehicles in purchasing payment rights under corporate tax. Legal counsel should review each of these investments in light of the specific provisions of the TRA and the due diligence of the company that is required to make the TRA payments. (State) Alaska Alabama Arkansas Arizona California Colorado Connecticut District of Columbia Delaware Florida Georgia Iowa Idaho Kansas Kansas Louisiana Massachusetts Maryland Minnesota Mississippi Montana North Carolina North Dakota Nebraska New Hampshire New New Mexico New Mexico New Mexico New Mexico New Mexico York Ohio Ohio Oregon Pennsylvania Rhode Island South Dakota South Tennessee Texas Virginia Virginia Virginia Vermont Washington Wisconsin West Virginia Wyoming The two most common forms of TRAs are „NOL TRAs“ and „Step-Up TRAs“ : legal counsel should have a thorough understanding of the legal, fiscal and economic impact of KRAA before they can be included in an IPO or in a transaction of M-D. Penalford Webbinaires are supported by our 100% unconditional refund guarantee: If you are not satisfied with any of our products, let us know and receive a full refund. Contact us at 1-800-926-7926. CLE On Demand Webinars are available 48 hours after the live program and include video broadcast of the full program plus flyers. They are available 24 hours a day, 7 days a week.

You can listen to the entire program in one session or take a break and go back to where you left off. Strafford offers one year of continuous access to every on-demand program you purchase. I thought the program was very well organized and presented. Strafford`s live webinars offer you a high-quality, economical and convenient CLE option, without wasting time or travel expenses.