Chapman and Cutler has considerable experience addressing the tax aspects of asset- and mortgage-backed securitizations and related derivatives transactions. We regularly provide structuring advice, opinions, and tax disclosure on federal, state, and local tax issues relevant to such transactions, including debt for tax, grantor trusts, stripping trusts, owner trusts, REMICs, REITs, offshore entities, and comparable structures. Chapman’s tax attorneys also have substantial experience in dealing with cross-border tax issues that arise in securitizations.
Our tax attorneys actively participate in advising clients in the structuring of securitization transactions as well as the ongoing reporting and administration of those transactions. Our tax attorneys also advise investors on the tax consequences of securitization investments. When necessary, we obtain rulings and guidance from the IRS and local taxing authorities to provide clients with a comprehensive understanding of the related tax implications of issuing or investing in a particular securitization transaction.