Securities & Finance / Industry Custom and Practice
Financial Services Risk Management Processes

Brattle principals consulted, as experts, for a foreign tax authority investigating a tax avoidance scheme that relied on a complex circular flow of funding. Brattle analyzed the vehicles used in the circular flow, which involved simultaneous debt issuance and collective trust purchases. Advice provided by Brattle on the customary corporate practice in structuring and documenting corporate subordinated debt issuances, as well as the due diligence and monitoring of purchased interests in a collective trust, enabled the tax authority to achieve a favorable tax settlement.