Bankruptcies & Restructurings
Our Tax attorneys work closely with our Bankruptcy & Restructuring group to best serve our clients on a variety of complex restructurings and workouts. We represent lenders as well as debtors and have extensive experience in the tax aspects of bankruptcy and insolvency workouts. We advise on utilization of, and limitations on, companies' net operating losses and other tax attributes, as well as the tax consequences of alternative workout scenarios, in order to structure transactions in the most tax-efficient ways and help companies emerge in the best financial position possible.
Experience Highlights
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Ad hoc group of term lenders comprised of Eaton Vance, Silver Point Capital, Symphony Asset Management, Franklin Mutual Advisors LLC, Beach Point Capital, Highland Capital, and Voya Investment Management that was owed more than $1.6 billion in the successful restructuring of Cumulus Media Inc. The transaction structure was carefully designed to achieve beneficial tax consequences and create additional value in the reorganized debtor in the form of increased tax attributes going forward.
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Ad hoc group of term lenders to iHeart Media Inc.—comprised of more than 50 funds managed by Eaton Vance, OppenheimerFunds and Symphony Asset Management—in the successful restructuring of iHeart's approximately $16 billion of debt and the separation of iHeartMedia and Clear Channel Outdoor Holdings Inc., a pre-reorganization subsidiary of iHeart, into two independent, publicly traded companies. The restructuring and separation capped a complex, multiyear effort in which we worked across multiple practice areas and offices to negotiate and evaluate various alternative restructurings and their tax consequences prior to implementing the plan that maximized the value to the creditors and the tax attributes of the company going forward.
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Deutsche Bank Trust Company Americas (as administrative agent) and a group of lenders (led by Eaton Vance, Credit Suisse, Invesco, and OppenheimerFunds) in the "first of its kind for a defense contractor" debt-for-equity, out-of-court restructuring of IAP Worldwide Services Inc. and certain of its subsidiaries and affiliates.
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NexBank SSB, as agent to the senior secured lenders to radio station operator AR Broadcasting LLC, in AR Broadcasting's debt-for-equity restructuring.
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