Tax issues on stake sales and investment into managers: structuring, pitfalls and steps to take now
About
Christine advises the private capital industry on derivatives, debt trading and structured products.
Christine's clients include credit funds, private equity funds, asset managers, hedge funds, financial institutions and high net-worth individuals. She specialises in structuring bespoke products, combining expertise across derivatives, repo, secondary debt trading and structured finance to arrive at highly targeted, pragmatic solutions tailored to the client's commercial objectives.
Christine advises on:
- currency sleeve hedging for credit funds,
- prime brokerage arrangements,
- structure repo transactions for emerging market sovereigns
- interest rate hedging,
- loan syndication and back leverage using total return swaps and sub-participations,
- equity derivatives including synthetic long and short positions,
- credit default swaps and opportunistic credit strategies,
- total return swaps on loans and bonds
- deal contingent hedging in connection with corporate acquisitions and divestments
- regulatory issues arising under EMIR, UK EMIR, SFTR and MiFID.
Christine is a regular contributor to Macfarlanes' Private Capital Solutions website and has co-authored thought leadership pieces on currency sleeve hedging and asset-specific financing solutions for credit funds.
Prior to joining Macfarlanes, Christine was an executive director at a Magic Circle law firm, creating and building specific legal solutions for clients using technology and new resourcing models. Christine has broad experience advising on large-scale dislocation projects for global banks, including IBOR transition and UMR implementation.
Christine has undertaken a number of secondments at global banks and has worked in London, Paris and Hong Kong.
Experience
- Advising a leading opportunistic fund on a repo and back-to-back sub-participation secured over emerging market sovereign bonds to provide financing to the central bank of the same sovereign.
- Advising a leading opportunistic fund on the purchase of a £145m inflation-linked loan and related inflation swap in respect of a distressed utility company which was undergoing a restructuring.
- Acting for a secondaries investment fund on a co-investment arrangement with a family office involving an outright transfer of loans under two facilities and related local law security.
- Advised an emerging markets asset manager on a $112m financing structure using option and forwards to launch a new commodity-backed currency for an emerging market sovereign.
- Advised a leading credit fund on single-asset total return swaps as part of a back leverage solution offered by various investment banks. Advice covered the applicability of leverage caps, indebtedness restrictions in subscription facilities, regulatory advice and commercial advice on negotiation points.
- Advising a leading credit fund on the sale of a portfolio of non-performing loans and related corporate vehicles structured via a series of sub-participations.
- Advising an emerging markets fund on a $150m structured repo to an emerging markets sovereign wealth fund and related back-to-back hedging arrangements.