Structuring, Regulatory, Tax, Distribution and Operational Advice

Working closely with our Finance & Restructuring, Tax and Regulatory practices, we additionally provide structuring, regulatory, tax, distribution and operational advice on:

Implementation

Implementation

Implementing lending strategies (including structuring downstream lending or investment architecture) and financing requirements.
European and UK regulation

European and UK regulation

Pan-European and UK regulatory and security issues for direct lending/loan origination, mezzanine and secondary loan strategies.
Solvency II/insurer investors

Solvency II/insurer investors

Solvency II analysis and structuring advice where investors would EU, UK and/or Swiss insurance companies.
German pension investors

German pension investors

Structuring solutions where investors would include categories of German pension plans subject to restrictions on investments into debt funds.
US direct lending - ECI tax issues for non-US investors

US direct lending - ECI tax issues for non-US investors

Where US direct lending features, we explore structuring solutions that minimise the twin impacts of ECI taxation on returns and US tax filings for non-US investors, including "Treaty" funds (or "independent agent" funds), “Season & Sell" funds, and leveraged US blockers.

We work with a large number of clients, including:

Direct lending/senior debt fund managers
Mezzanine debt fund managers
Credit opportunities fund managers
Distressed debt fund managers
Real estate debt fund managers
Venture debt fund managers
Speciality finance fund managers
Fintech lenders, including online lending platforms
Financial sponsors
Lending syndicates
Institutional investors investing in co-investments or JV lending or debt investment programmes.