Kurt Baca is a member of the firm’s Tax Practice Group. He has a diverse transactional and planning practice ranging from advising on bank mergers…
Kurt Baca is a member of the firm’s Tax Practice Group. He has a diverse transactional and planning practice ranging from advising on bank mergers and acquisitions, including mutual bank mergers, REIT structuring and qualification issues, internal reorganizations, various debt financing transactions, including convertible debt issuances with integrated bond hedges and capped calls, project finance, currency hedging and related straddle issues, interest deductibility planning, including section 163(j) planning, the use of REMIC residual interests, and the use of various financial products for efficient investment structures and intra-group tax asset utilization. Much of his work involves cross-border issues, subpart F and NCTI (formerly GILTI) planning, and PFIC issues.
While his practice is diverse, Kurt is particularly interested in innovative uses of financial products and fundamental tax issues relating to the character of income, tax ownership, debt/equity, economic substance, and aggregate vs. entity treatment of pass-through entities as they relate to planning tax-efficient transactions and structures. Recent examples of Kurt’s projects include:
Advising asset managers on innovative derivative investments in various types of funds, involving swaps and variable forward contracts;
Advising on the development of structured notes to be acquired by life insurance companies to support variable annuity contracts and private placement life insurance contracts;
Advising on the availability of the dividends received deductions for dividends received on shares of a basket of stock acquired to hedge the risks related to writing options on equity indices;
Advising on the use of revenue strips in intra-company/intra group transactions to effectively use tax attributes;
Advising on the structuring of bond hedges and capped call options acquired in connection with the issuance of convertible debt to meet the requirements for tax integration;
Advising on the use of commodity swaps to transfer income risks and benefits between member of a multi-national group of companies;
Advising on the structuring of off-shore energy projects to assure the desired income treatment for U.S. tax purposes; and
Advising a REIT on the use of REIT subsidiaries and protective trusts to meet REIT qualification requirements.
Some of this work has included advising clients on issues connected with acquiring tax insurance.
Kurt has nearly 30 years of experience. He has advised on a significant variety of innovative transactions over that time. Those transactions have, among other things, involved foreign tax credits, contingent payment debt instruments, credit default swaps, and partnership allocations. He has also represented issuers and underwriters in the development and execution of high profile capital market transactions, including various forms of convertible debt and structured investment units. Kurt has experience in advising clients in controversies arising from corporate financing transactions.
Kurt Baca is a member of the firm’s Tax Practice Group. He has a diverse transactional and planning practice ranging from advising on bank mergers…
Kurt Baca is a member of the firm’s Tax Practice Group. He has a diverse transactional and planning practice ranging from advising on bank mergers and acquisitions, including mutual bank mergers, REIT structuring and qualification issues, internal reorganizations, various debt financing transactions, including convertible debt issuances with integrated bond hedges and capped calls, project finance, currency hedging and related straddle issues, interest deductibility planning, including section 163(j) planning, the use of REMIC residual interests, and the use of various financial products for efficient investment structures and intra-group tax asset utilization. Much of his work involves cross-border issues, subpart F and NCTI (formerly GILTI) planning, and PFIC issues.
While his practice is diverse, Kurt is particularly interested in innovative uses of financial products and fundamental tax issues relating to the character of income, tax ownership, debt/equity, economic substance, and aggregate vs. entity treatment of pass-through entities as they relate to planning tax-efficient transactions and structures. Recent examples of Kurt’s projects include:
Advising asset managers on innovative derivative investments in various types of funds, involving swaps and variable forward contracts;
Advising on the development of structured notes to be acquired by life insurance companies to support variable annuity contracts and private placement life insurance contracts;
Advising on the availability of the dividends received deductions for dividends received on shares of a basket of stock acquired to hedge the risks related to writing options on equity indices;
Advising on the use of revenue strips in intra-company/intra group transactions to effectively use tax attributes;
Advising on the structuring of bond hedges and capped call options acquired in connection with the issuance of convertible debt to meet the requirements for tax integration;
Advising on the use of commodity swaps to transfer income risks and benefits between member of a multi-national group of companies;
Advising on the structuring of off-shore energy projects to assure the desired income treatment for U.S. tax purposes; and
Advising a REIT on the use of REIT subsidiaries and protective trusts to meet REIT qualification requirements.
Some of this work has included advising clients on issues connected with acquiring tax insurance.
Kurt has nearly 30 years of experience. He has advised on a significant variety of innovative transactions over that time. Those transactions have, among other things, involved foreign tax credits, contingent payment debt instruments, credit default swaps, and partnership allocations. He has also represented issuers and underwriters in the development and execution of high profile capital market transactions, including various forms of convertible debt and structured investment units. Kurt has experience in advising clients in controversies arising from corporate financing transactions.
