Politics and money converged when the United States agreed recently to back Ukraine with $1 billion in financing, and Arnold & Porter Partner Cynthia Mann helped the underwriters negotiate the tax issues.
J.P. Morgan and Morgan Stanley underwrote the deal, which was authorized by Congress and issued by USAID as part of the U.S. government’s economic and political support for Ukraine. In the transaction, Ukraine issued $1 billion of five-year notes, fully guaranteed by the United States, at an interest rate of 1.844 percent.
“The proceeds of the $1 billion guaranteed bond will strengthen the government of Ukraine’s ability to protect the most economically vulnerable Ukrainians from the impact of necessary economic adjustments, for example, by supporting expansion of the social safety net,” Mann told WIPL. “The U.S. guarantee demonstrates the strong U.S. commitment to the people of Ukraine, enabling Ukraine to access affordable financing from international capital markets. To date, there have been 19 sovereign debt offerings guaranteed by the United States, and Arnold & Porter has represented either the sovereign government or the underwriters on 18 of the 19 transactions.”
According to a U.S. Treasury press release, the $1 billion loan guarantee is part of a U.S. bilateral assistance package that also includes technical assistance.
Mann worked on the tax side, while the Arnold & Porter corporate team consisted of partner Steven Tepper and associates Rebecca Crawford and Raquel Saavedra.
Mann is a partner in the tax, trusts, and estates practice at Arnold & Porter and has more than 20 years of experience in transactional domestic and cross-border tax law. She concentrates her practice on the federal, state and cross-border tax issues associated with tax-free and taxable acquisitions, sales and combinations of incorporated and unincorporated entities and their assets; equity and debt restructurings in bankruptcy and insolvencies; hedge and private equity funds; U.S. and international securities offerings, tax planning using S corporations, trusts, partnerships, REITs, RICs and limited liability companies; and executive compensation.
Mann is the administrative partner of Arnold & Porter’s New York office and also serves on the firm’s Management Committee and Billing and Intake Committee.