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Qualifications

  • Founding Principal
  • Other Senior Resources
  • Securities & Capital Markets Litigation
    • Characterization of Complex Structured Transactions for Tax Litigation
    • Securities Litigation - Misrepresentation of Risk
    • Securities Contract Litigation of an International Bank’s Loan & Collateral Practices
    • Large Securities Class Action Litigation
    • Tax Litigation focused on the Economic Substance
    • Drafted Request for Production of Documents for Structured Transactions at Financial Institutions
    • Trading Fraud Investigation
    • Provided Discovery Support for Large Securities Litigation
    • Criminal Tax Fraud Case Uncovered Economic Substance in the Structure of Investment Transactions
    • Analyzed Brokers Responsibilities Related to Commodity Transactions
    • Estimated Transactions Costs
    • Investigation of Fraud and Created Foundation
    • Securities Contract Disputed Estimation
    • Securities Litigation Recreated
  • Capital Markets Consulting

Characterization of Complex Structured Transactions for Tax Litigation

Activity:

  • Analyzed the economic and capital markets characteristics of complex structured transactions. The dispute focused on whether or not the transactions should be characterized as loans or sales

Results:

  • Evaluated and quantified the financial risks of the unique capital market features of the structure. Although documented as a sale, the analysis of the financial risks revealed that in substance, the structures were loans. Our analysis was based upon industry practices in the capital markets.
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