Baker Botts tax lawyers routinely advise clients on the design, purchase and sale of financial instruments such as indebtedness (including convertible debt, variable rate debt and contingent payment debt), equity (including common and preferred stock), notional principal contracts (e.g., swaps), options, forward contracts and credit derivatives. We have acted as counsel to a variety of issuers of sophisticated financial instruments in audit proceedings before the Internal Revenue Service. We use our experience and knowledge of the complex tax rules in this area to help our clients achieve their business objectives.
Our lawyers also advise on tax issues associated with commercial credit facilities, letter of credit facilities, mezzanine financings, note purchase agreements, debt restructurings, structured financings and leasing transactions. Our lawyers have extensive experience with U.S., non-U.S. and cross-border commercial credit facilities, both syndicated and single-lender, including working capital, bridge, and acquisition facilities, project financings and asset-based financings.