Tax structure memos: a guide

Author: | Published: 8 Jul 2019

In an era where documentary terms and security and guarantee packages in leveraged finance deals are under increasing pressure, it is important for both sponsors and lenders to focus on the robustness of the acquisition structure, as well as the quality and clarity of advice, contained in the tax structure memorandum (or structure memo). The structure memo provides sponsors with important tax-efficient structuring advice for the initial transaction and any possible exit scenario. It also provides lenders with information on ongoing payments to be made by the acquired group, the tax status of the original and possible syndicate of lenders and shows the position of their debt, security and guarantee claims in the group structure....