LOL.... Yeah, here's some constructive criticism. Credit Suisse is the DIP Agent, not the DIP Lender. There are several DIP Lenders (I thought even you knew that). Although some of the DIP Lenders are not domiciled in the US and some of the US-domiciled DIP Lenders may be tax-exempt entities, their membership interests in the DIP's newco must be held in Tent Blocker, a US company domiciled in the State of Delaware. Tent Holding, LLC will also be a Delaware limited liability company, as will GoM Bidco, LLC. Do they pay income tax in Delaware?
Now here's a puzzler for you, Billy. If "the use of a Cayman Islands entity by a Swiss bank to hide income taxes reveals that the DIP lender really does expect a windfall profit from the transaction", does the use of domestic companies that don't hide income taxes reveal that the DIP Lenders really don't expect a windfall profit from the transaction?
I think the answer to this question is "no", but what do I know, eh?
|