Grant has been part of the teams advising:
- A major financial institution, as administrative agent, in a $1 billion senior secured term and revolving facility for Krispy Kreme Doughnuts Inc., to refinance existing indebtedness
- Citi, as administrative agent, in $800 million unsecured revolving and term facilities for Masimo Corporation to finance its acquisition of Sound United LLC
- Clairence Technologies, Inc. (a portfolio company of Genstar Capital) in its acquisition of Pressure Systems International, LLC and the assets of Truck System Technologies, Inc.
- Covetrus, Inc. in its $4 billion sale to CD&R, a holder of approximately 24% of Covetrus' outstanding common stock, and TPG
- First Light Acquisition Group in its pending merger with with Calidi Biotherapeutics, Inc.
- An affiliate of Goldman Sachs Asset Management, as administrative and collateral agent, in $820 second lien term facilities to finance in part Brookfield Asset Management's $8.3 billion acquisition of CDK Global, Inc.
- JPMorgan Chase, as lead arranger and administrative agent, in a $400 million senior secured revolving facility for Etsy Inc.
- Kenect, LLC (a portfolio company of PSG) its acquisition of Friendemic Inc.
- The Kroger Company in its pending $24.6 billion merger with Albertsons Companies, Inc.
- Main Event Entertainment, Inc. (a subsidiary of Ardent Leisure Group Limited in which RedBird Capital is a minority investor) in its $835 million sale to Dave & Buster’s, Inc.
- Redbox Entertainment Inc. in its sale to Chicken Soup for the Soul Entertainment, Inc.
Grant received his LL.M., with distinction, from Georgetown University Law Center, where he made the Dean’s List and was a recipient of the CALI Award for Tax Planning for Corporate Acquisitions Seminar. He received his J.D. from Georgetown University Law Center, where he served as Senior Executive Editor of the Georgetown Immigration Law Journal, and his B.A., cum laude, from Harvard University, where he was a recipient of the Susan Anthony Potter Prize and the Ned Weld Above and Beyond Award. He is fluent in Spanish and Portuguese.
Awards and Recognition, Speaking Engagements, Guides and Resources, Latest Thinking, Firm News & Announcements
IP Phone Home – IRS Issues New Proposed Rules on the Repatriation of Intangible Property
Blog Post — Tax Blog
Graham Magill and
— May 04, 2023
Section 367(d) of the Internal Revenue Code (the “Code”) provides rules for outbound transfers of intangible property (e.g., intellectual property) by a U.S. person (a “U.S. transferor”) to a foreign corporation. Under these rules, when a U.S. transferor transfers intangible property to a foreign corporation in an otherwise tax-free exchange under Sections 351 or 361, the U.S. transferor is treated as having sold the intangible property in exchange for annual royalty payments (an “annual inclusion”) over the useful life of the intangible property (or a lump sum payment in the case of a disposition of the intangible property following the initial outbound transfer). The U.S. transferor treats the annual inclusion and lump sum as ordinary income and royalties for purposes of determining source and the foreign tax credit limitation category. Final regulations under Section 367(d) were published on December 16, 2016 (the “367 Regulations”). ...
- Corporate Tax 2023 — USA: Law & Practice and USA: Trends & Developments Publication — Chambers Global Practice Guides — By Devon Bodoh, Joseph M. Pari, Greg Featherman, Alex P Dobyan and Grant Solomon — PDF — April 14, 2023
State of the Union: President Biden Calls for Increase to the Excise Tax
Blog Post — Tax Blog
Devon Bodoh and
— February 08, 2023
The Inflation Reduction Act of 2022 imposes a one percent excise tax (the “Excise Tax”) on the repurchase of corporate stock under Section 4501 of the Internal Revenue Code (“Section 4501” and the “Code”, respectively) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. Much welcome guidance was released on December 27, 2022 in Notice 2023-2 (the “Notice”), which provides taxpayers with interim guidance until proposed regulations are issued. For purposes of the Excise Tax, the term covered corporation means any domestic corporation whose stock is traded on an established securities market (within the meaning of Section 7704(b)(1)). A covered corporation also includes any corporation that becomes a surrogate foreign corporation under Section 7874(a)(2)(B) after September 20, 2021. A repurchase of corporate stock by a covered corporation, to which the Excise Tax applies, generally includes (i) redemptions within the meaning of Section 317(b) and (ii) transactions determined by the Secretary of the Treasury or her delegate to be economically similar to a 317(b) redemption. The liability for any Excise Tax may be offset by stock issuances in the same taxable year or other exceptions detailed in the Notice. ...
Notice 2023-2: Proposed Guidance on the Stock Buyback Excise Tax
Blog Post — Tax Blog
Madeline Joerg and
— December 29, 2022
The Inflation Reduction Act of 2022 imposes a one percent excise tax (the “Excise Tax”) on the repurchase of corporate stock under Section 4501 of the Internal Revenue Code (“Section 4501” and the “Code”, respectively) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. For purposes of the Excise Tax,
The post Notice 2023-2: Proposed Guidance on the Stock Buyback Excise Tax appeared first on Weil Tax BLOG....
SPACs and the 1% Excise Tax
Blog Post — Tax Blog
Grant Solomon and
— October 19, 2022
The Inflation Reduction Act of 2022 (the “IRA”) imposes a 1% excise tax on the repurchase of corporate stock (the “Excise Tax”) by a publicly traded U.S. corporation following December 31, 2022. ...
Firm News & Announcements
- Weil-Led Deal Recognized for M&A Deal of the Year at the 2023 D CEO and Association for Corporate Growth-DFW Mergers & Acquisitions Awards Deal Brief — May 08, 2023
- Weil Advises Advent International on its Investment in China-based LBS Group Deal Brief — March 01, 2023