Michael Marion

As a partner in the Tax Transactions group, Michael K. Marion focuses on advising clients on the tax aspects of a broad range of transactions, including structured and leveraged finance transactions, capital markets transactions and securitizations (including CLO transactions), as well as taxable and nontaxable mergers and acquisitions.

He also regularly advises clients on international, corporate and consolidated return tax issues as well as financial products, FATCA and derivatives (including ISDA documentation).

Education :

• New York University School of Law, LLM
• The George Washington University Law School, JD, with honors
• University of Michigan, BA, in Psychology

Admissions : New York

Experience :

• Represented domestic mortgage servicing company in multi-tranche servicer advance securitization with a note principal balance of +$1 billion.
• Represented Canadian financial institution in excess loss note (ELN) take out restructuring for its U.S. commercial paper conduit.
• Represented leading global asset manager in multiple CLO transactions with note principal balances of +$1 billion, including representation of CLO issuer.
• Represented global financial institution in $400 million regulatory capital hybrid security issuance involving Asia, Australia and the United States.
• Represented global financial institution in multiple cross-border tax-free spin-offs.
• Represented global financial institution in obtaining private letter rulings relating to the application of the consolidated return regulations and Code section 382, respectively.
• Represented Canadian global financial institution in a tax-free internal restructuring of its U.S. business, relating to the integration of new and legacy businesses.
• Represented global financial institution as lender and administrative agent in +$600 million credit facility that included a term loan, revolving loan and a letter of credit.