Considerations When Purchasing Tax Receivable Agreements
By Adam Greenwood, Amanda Holt, Alfred Rose, Carl Marcellino and Thomas Holden (July 27, 2018, 4:04 PM EDT) -- The enactment of tax reform last December provided investors increased certainty regarding corporate tax rates for the near future. One consequence of this has been an increased interest by certain investors in purchasing payment rights under existing so-called "tax receivable agreements." Briefly, TRAs are agreements entered into by a company in connection with an initial public offering to monetize tax attributes of the post-IPO company for the benefit of pre-IPO owners and also investors who purchase rights to payment under TRAs from such pre-IPO owners. Our prior article on TRAs focused on some of the ways in which tax reform might...
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