Client alert · August 2026
Private Markets Meet Structured Finance
What rated-note feeders do to the blocker analysis
When a private-markets platform starts issuing rated tranches, the tax questions change shape.
In brief
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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This alert is for general information only and is not tax, legal, investment, or accounting advice. Consult your own advisers before acting. Carlos A. Schmidt, MBT, MBA, CPA · Managing Member · carlos@lapresallc.com · (917) 558-6393.