A boutique practice for investment managers, family offices, and private clients. We find the tax mechanism underneath the deal, walk the numbers, and give you a view.
Fund sponsors negotiating a continuation vehicle. Family offices deciding how to hold a stake. Individuals with more at risk in a single tax year than most firms see in a decade. Different seats, same question: what does this structure cost after tax, and can someone show me?
We can. Every engagement produces a memo and a workbook, and the two agree.
Feeders, parallels, SMAs, and leveraged blockers, with the ECI, withholding, and §163(j) arithmetic run rather than assumed.
Manager M&A, continuation funds, Up-C IPOs, and tax receivable agreements, with the gain computed before anyone signs.
Reasoned opinions at a stated level of comfort, technical memoranda, and private letter ruling requests.
Entity and trust design, PTET and multi-state planning, QSBS, Opportunity Zones, and the after-tax comparison of the choices in front of you.
IRS controversies and audits, §382 NOL preservation, partnership workouts, §174 studies, and forensic investment research.
ITC structuring, §6418 credit transfers, and tax-equity flips for developers and the investors funding them.
A position we cannot model is a position we do not yet understand.
La Presa Partners served as tax adviser to Trimontium on a bespoke $325 million package of debt, hybrid, and equity instruments for Authentic Restaurant Brands, a portfolio company of Garnett Station Partners.
What the cashing-out LP, the rolling LP, and the new money each give up when a sponsor moves a company into a continuation vehicle, with the basis and liability arithmetic laid out step by step.
Which tax metrics predict after-tax returns, which merely describe last year, and how selection bias, marks, and fee resets distort the comparisons most decks rely on.