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Covington provides advice on the development and use of financial products. We advise issuers on the structuring of innovative financial products. We also advise investors and other capital market participants on the tax consequences of sophisticated financial products and their application in various strategies. We represent clients before Treasury, the Internal Revenue Service and Congress in connection with obtaining appropriate tax treatment for financial products.
Our practice in the financial products area spans a broad range, encompassing domestic and international transactions, exchange-traded and over-the-counter products, hedging strategies, and more. We regularly advise clients on tax issues raised by new financial products, such as credit derivatives, structured debt, and exotic options. Our clients include US and foreign hedge funds, CDO sponsors, mutual funds, banks, pension trusts, corporations and wealthy individuals. We also have extensive experience in the development of insurance-based products. Our expertise is nationally recognized and our lawyers regularly speak and write in this area. Our client base permits us to keep abreast of new and emerging products and structures and we frequently represent clients before Treasury, IRS and Congress in resolving the treatment of new financial products and strategies.
Representative Matters
- Advice to mutual funds on the tax treatment of new financial products.
- Advice to pension trusts on tax treatment of new forms of credit derivatives.
- Represent coalition of options exchanges on legislative and regulatory developments affecting the tax treatment of options and option-based strategies.
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