Speaker details

Biography

Mark Leeds focuses his practice on the tax consequences of a variety of financial products and strategies, including digital assets, private funds, exchange-traded funds, litigation finance, life settlement, banking and insurance. Mark’s experience includes both exchange-traded and over-the-counter derivative transactions, and strategies for the efficient utilization of tax attributes—such as net-operating losses. Mark regularly works with financial institutions on developing products and the related tax reporting considerations. He also advises businesses and individuals in establishing operations and relocating to Puerto Rico and has a substantial practice in private credit transactions. Mark is well-known for his extensive writings on capital markets tax issues. A market-recognized tax authority in financial products and strategies who has been named to Legal 500’s list of Hall of Fame lawyers for Tax: Financial Products, Mark is best known for his client-focused approach to developing solutions to a variety of tax-related challenges faced by companies and individuals with exposure to existing and emerging asset classes. He regularly advises both buy-side and sell-side market participants in innovative insurance transactions, cross-border strategies and derivative transactions. A leading advisor in litigation finance transactions, Mark’s clients include some of the largest firms in the market obtaining exposure to litigation recoveries, and he also represents companies and firms accessing capital through this market. Mark has been one of the leading tax advisors to the life settlement market for over 20 years. He has led teams in fund formation, developing and implementing structures for large institutional investors to obtain exposure to this market and working with cross-border structures for private clients. Mark regularly works with insurance companies in structuring products that provide risk-based exposures to financial market returns, including private placement life insurance and annuities, as well as with U.S.- and non-U.S.-based financial institutions on tax issues presented by cross-border dealing operations, including the base erosion and anti-avoidance tax (BEAT), interest expense limitations, and the sale and development of financial products for both U.S. and non-U.S. clients. He is a market-recognized authority in tax issues presented by securities lending transactions, swaps, futures and forward contracts. Mark has a substantial advisory practice for companies with significant net-operating losses. He regularly advises such companies how to best structure operations and capital infusions in a manner that passes the numerous U.S. tax code limitations imposed on the use of such attributes. These strategies allow loss companies to rehabilitate their businesses and use their existing tax attributes to shelter income during this process.