Securitization & Structured Products Taxation


“They do cutting-edge financial product work and have good technicians in the area.” - Chambers USA

A significant portion of Cadwalader's tax practice includes advising the Firm's prominent financial services clients, including commercial and investment banks, insurance companies, funds, thrifts and financial intermediaries, regarding the structuring, documentation and execution of complex, tax-advantaged transactions and products in both the U.S. and abroad as well as helping them to address the tax ramifications of alternative strategies in distressed situations.

Since our groundbreaking work with the Treasury and the Internal Revenue Service in developing the regime for taxing asset-backed securities, Cadwalader has been the leader in structuring sophisticated securitization vehicles. Our tax attorneys have had leading roles in virtually every type of mortgage-backed and asset-backed securitization in the market. They also have extensive experience with other cutting edge capital markets products, including CDOs and other complex financial products, derivatives and specialized financing and investment vehicles.

  • Barclays, UBS and others on more than 2,000 structured note issuances with an aggregate face amount of over $1 billion
  • JPMorgan, Citibank, Blackstone, Sankaty, Credit Suisse, Oak Hill, DoubleLine, Goldentree and others on the formation of newly-organized multi-million dollar funds formed and in restructuring several funds, CDOs, and other investment vehicles
  • Goldman Sachs & Co. in the highly publicized securitization of a loan made to Developers Diversified Realty Corp, the first new issue of CMBS under the TALF program
  • Freddie Mac in its first ever multi-family CMBS transaction, a hybrid structure similar to a conventional CMBS transaction with Freddie guaranteeing the senior bonds
  • Bank of America in a $460 million property financing related to 44 office and industrial properties in Florida
  • Principals in the formation of C12 Capital Management LP, an asset management firm that will manage assets, including U.S. residential and commercial mortgage backed securities, of Protium Finance LP, a fund that purchased more than $12 billion of credit market assets from Barclays PLC
  • JPMorgan Private Bank on tax issues with respect to the Blackstone Real Estate CMBS Fund

3 Attorneys

Blakemore, Adam Partner London
T. +44 (0) 20 7170 8697
Howe, Mark P. Partner Washington
T. +1 202 862 2236
Silverstein, Gary T. Partner New York
T. +1 212 504 6858