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Services

Securitization Tax Services

Tax reporting for CLOs

Deloitte’s Securitization Tax practice is experienced at providing leading tax preparation services to US equity investors (investors), focusing on after-tax returns. We routinely assist collateralized loan obligation (CLO) portfolio managers, trustees, and underwriters with new and emerging industry issues, such as the implications of new tax structures, legislation, and reporting requirements.

Tax services for complex financial transactions

Our Securitization Tax professionals specialize in tax reporting for CLOs. Our team of more than 70 specialists is well informed on international and domestic tax developments that affect CLOs and investors. We regularly consult with clients on potential opportunities to improve the after-tax return for investors. Additionally, our Securitization Tax specialists are adept at addressing the tax issues of offshore entities with US trade or business concerns, including preparing tax filings for blocker subsidiaries.

Securitization arrangement types

We perform tax services for more than 1,000 CLOs and other structured finance transactions (e.g., real estate mortgage investment conduits (REMICs), collateralized debt obligations, and real estate investment trusts (REIT)). We have experienced the tax complexities associated with risk retention structures and other vehicles investing in CLO equity. Our tax reporting services include a variety of securitization arrangements including:

  • CLOs
  • Commercial real estate CLOs
  • Multifunctional currency CLOs (e.g., US dollar, euro, and pound sterling)
  • Partnership securitizations
  • Refinancings and resets
  • Resecuritizations
  • Partnerships, including CLO funds, that invest in CLO securities and equity
  • Trust and insurance preferred CDOs
  • Multi-sector CDOs (e.g., CMBS, residential mortgage-backed securities (RMBS), and other asset-backed securities (ABS))

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How Deloitte can help

Our turnkey solution for US investor tax reporting includes analyzing each CLO’s asset composition and investor base before advising on tax accounting method selection. A sample of the tax services we offer to investors to help them think ahead and prepare for securitization transactions include:

  • Selection of optimal tax accounting methods and conventions
  • Turnkey preparation of annual tax-basis records from trustee-provided information
  • Prepare future projections of income based on various assumptions to facilitate tax planning
  • Determining the annual tax status of CLOs (e.g., the Controlled Foreign Corporation [CFC] or Controlled Foreign Partnership [CFP])
  • Preparation of annual PFIC or partnership tax reporting for CLOs
  • Preparation of personalized investor reporting, such as IRS Forms 5471 and 8865
  • Consultation on the impact of the Tax Cuts and Jobs Act (The 2017 Tax Act) on securitization transactions and investors
    • Limitation on deduction for business interest expense
    • Transfers of partnership interests
    • Subpart F rules, including changes to the definitions of CFC and United States shareholder (US shareholder)

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A trusted leader in securitization

With Deloitte Tax LLP (Deloitte Tax), you can expect leadership, guidance, and service. In the last 25 years, we have performed structuring and tax preparation services for thousands of transactions. Our clients depend on us for thought leadership when analyzing tax planning. We bring our depth and breadth of accounting, tax, and regulatory knowledge coupled with deep securitization and international tax experience to guide investors through complex and potentially unexpected tax issues.

Deloitte Tax offers:

  • A leadership team with each having 15 to 30 years of securitization and international experience, completing thousands of transactions
  • A dedicated team of 70 professionals
  • Tax services for more than 1,000 CLOs and other securitization arrangements
  • Tax services for many of the top 10 CLO managers
  • A turnkey approach
  • Proprietary tax software, Solvas | CLO Tax, for calculating tax earnings and profits and taxable income on securities held as collateral for CLOs, including the implementation of various tax elections

2020 GlobalCapital US securitization awards

Deloitte is honored to be the recipient of the following 2020 GlobalCapital US Securitization Awards:

  • Best Securitization Accounting Firm of the Year
  • Buyside Accounting Firm of the Year
  • Sellside Accounting Firm of the Year 

On behalf of the Deloitte Securitization practice, we would like to express our appreciation to our clients and industry participants for their valued support and continued collaboration. We are honored and grateful to have been recognized amongst our peers for outstanding achievement across the structured finance industry. We’d also like to thank GlobalCapital for hosting these awards and their commitment to the capital markets.

Key contacts

Joelle Berlat
Tax managing director

Deloitte Tax LLP
+1 713 982 4085

Mandy VanVelzel
Senior manager

Deloitte Tax LLP
+1 713 982 3656

Sarah Burden
Senior manager

Deloitte Tax LLP
+1 713 982 2160

James Cook
Tax principal

Deloitte Tax LLP
+1 713 982 4184

Brittney Duffy
Managing director

Deloitte Tax LLP
+1 713 982 3618

Andy Ginsburg
Managing director

Deloitte Tax LLP
+1 713 982 4284

Shawn Guarisco
Senior manager

Deloitte Tax LLP
+1 713 982 3719

Chris Hester
Managing director

Deloitte Tax LLP
+1 713 982 4448

Michelle Markowitz
Managing director

Deloitte Tax LLP
+1 713 982 4265

Vivian Peng
Senior manager

Deloitte Tax LLP
+1 713 982 4150