Taxation of Structured Instruments


We have extensive experience in advising large financial institution clients on a broad range of capital markets transactions, derivatives and financial instruments.

We advise clients in structuring and analyzing innovative tax-efficient financial products and transactions, including deductible hybrid securities, trust preferred securities, hedge fund and commodity-linked derivatives, convertible debt, contingent convertible debt instruments, structured notes, mandatory and optionally convertible instruments, domestic and cross-border notional principal contracts (such as swaps, caps and floors), collars, options, futures and forward contracts, securities lending, repurchase contracts and other hedging transactions, including with respect to foreign currencies, and credit derivatives.

We also advise clients on debt and equity shelf registrations, the original issue discount rules, variable rate debt instrument and contingent debt rules, debt reopenings, debt exchanges and recapitalizations, foreign targeted securities offerings, withholding tax implications, and compliance with reporting rules.

We are at the cutting edge. IFLR1000 US notes that it is in the “…structured finance space that the firm’s innovative role comes across most markedly.”

Chambers Global 2017
United States: Capital Markets: Derivatives


Chambers USA 2017
National: Tax Controversy
California: Tax
New York: Tax
National: Capital Markets: Derivatives
National: Capital Markets: Securitization (Individual Partners Ranked)
National: Capital Markets: Structured Products (Individual Partners Ranked)


EQDerivatives Awards 2016
Equity Derivatives Law Firm of the Year


GlobalCapital Americas Derivatives Awards 2015, 2016, 2017
Americas Law Firm of the Year


GlobalCapital Global Derivatives Awards 2016
Global Law Firm of the Year


IFLR1000 2017
United States: Capital Markets: Derivatives
United States: Capital Markets: Structured Finance and Securitisation
United Kingdom: Capital Markets: Derivatives


IFLR Americas Awards
Structured Finance and Securitisation Team of the Year, 2015
Structured Finance and Securitisation Deal of the Year, 2013


Law360
2013 Tax Practice Group of the Year


Legal 500 UK 2015
Derivatives and Structured Products Securitisation


Legal 500 US 2016
International: Tax
US Taxes: Financial Products
US Taxes: Contentious
US Taxes: Non-Contentious
Structured Finance


mtn-i Americas Awards 2013
Legal Leader


StructuredRetailProducts.com 2012, 2013, 2014, 2015
Best Law Firm in the Americas


Structured Products magazine 2006, 2007, 2009, 2011, 2012, 2014, 2016
Law Firm of the Year, Americas


U.S. News Best Lawyers® Best Law Firms 2017
National: Litigation – Tax (Tier 1)
National: Tax Law (Tier 1)
New York: Litigation – Tax (Tier 1)
New York: Tax Law (Tier 1)
Sacramento: Litigation – Tax (Tier 1)
San Francisco: Litigation – Tax (Tier 1)
San Francisco: Tax Law (Tier 1)
Washington, D.C: Litigation – Tax (Tier 2)
Washington, D.C: Tax Law – (Tier 1)


U.S. News Best Lawyers® Law Firm of the Year 2016
Litigation – Tax

Thomas A. Humphreys
Partner
New York
(212) 468-8006

U.S. News – Best Lawyers® Law Firm of the Year 2016
Litigation – Tax

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