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 impact the value of TRA payment rights.[1] Since the enactment of tax reform, we have witnessed a substantial increase in investor interest in acquiring TRA payment rights, particularly by hedge funds, family offices and special purpose private investment funds. This article describes some of the features of a TRA that an investor should analyze prior to acquiring rights under a TRA....

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