The Second Exit
What the cashing-out LP, the rolling LP, and the new money each give up when a sponsor moves a company into a continuation vehicle, with the basis and liability arithmetic laid out step by step.
Each one takes a live market event, finds the tax mechanism underneath it, walks the numbers, and ends with a view. Subscribe by email · RSS
A multi-instrument package, with capital drawn over time as the business grows, is exactly the kind of structure where the tax analysis has to be done seat by seat.
La Presa Partners served as tax adviser to Trimontium on a bespoke $325 million package of debt, hybrid, and equity instruments for Authentic Restaurant Brands, a portfolio company of Garnett Station Partners.
What the cashing-out LP, the rolling LP, and the new money each give up when a sponsor moves a company into a continuation vehicle, with the basis and liability arithmetic laid out step by step.
Which tax metrics predict after-tax returns, which merely describe last year, and how selection bias, marks, and fee resets distort the comparisons most decks rely on.
What a rated-note feeder does to the blocker analysis, how the insurer buying the senior tranche sees the same cash flows differently, and where the §163(j) and withholding questions land once the capital stack has three layers.
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