Grant Solomon

Associate Washington, D.C.

Biography

Grant Solomon
Grant Solomon is an associate in Weil’s Tax Department and is based in Washington, D.C. Grant participates in the representation of Firm clients with respect to the tax aspects of a wide range of corporate transactions, including domestic and cross-border mergers and acquisitions, joint ventures and financing transactions.

Grant has been part of the teams advising:

  • A major financial institution, as administrative agent, in a $1 billion senior secured term and revolving facility for Krispy Kreme Doughnuts Inc., to refinance existing indebtedness
  • Advent International in the investment in LBS Group
  • Special Committee of the Board of Directors of Agiliti, Inc. in its merger with affiliates of Thomas H. Lee Partners, L.P in a transaction that implies an enterprise value of approximately $2.5 billion
  • Blue Bird Corporation (a portfolio company of American Securities, LLC) in a $250 million senior secured term and revolving facility
  • Blue Bird Corporation and an affiliate of American Securities, LLC, as selling stockholder, in a $52.5 million secondary offering of 2,500,000 shares of common stock and, in a $63 million secondary offering of 2,500,000 shares of common stock, and in a $133 million secondary offering of 4,042,650 shares of common stock
  • Brookfield Asset Management, Inc.
    • in its formation of Brookfield Infrastructure Fund V, L.P., a $30 billion global infrastructure fund
    • in the formation of Brookfield Infrastructure Debt Fund III, LP, a $6 billion infrastructure debt focused fund
  • Churchill Capital VII in its pending $1.58 billion business combination with CorpAcq Holdings Limited
  • Citi, as administrative agent, in $800 million unsecured revolving and term facilities for Masimo Corporation to finance its acquisition of Sound United LLC
  • Clarience Technologies, Inc. (a portfolio company of Genstar Capital) in its acquisition of Pressure Systems International, LLC and the assets of Truck System Technologies, Inc.
  • Covetrus, Inc. in its $4 billion sale to CD&R, a holder of approximately 24% of Covetrus' outstanding common stock, and TPG
  • Digital Realty Trust, Inc. in definitive agreements with Brookfield Infrastructure Partners L.P. and its institutional partners, Cyxtera Technologies and Digital Core REIT, that successfully resolve the relationships with Cyxtera, including its (i) $459 million sale of four data centers located in California and New Jersey, (ii) $44 million purchase and termination of three of Cyxtera’s leases in Germany and Singapore, (iii) assignment to Brookfield of three leases in Los Angeles and New Jersey and (iv) purchase option to acquire from Brookfield one colocation center outside of London
  • The Estée Lauder Companies Inc. in its $650 million offering of investment grade senior unsecured notes
  • First Light Acquisition Group in its merger with with Calidi Biotherapeutics, Inc.
  • An affiliate of Goldman Sachs Asset Management, as administrative and collateral agent, in $820 second lien term facilities to finance in part Brookfield Asset Management's $8.3 billion acquisition of CDK Global, Inc.
  • Galvanize Climate Solutions in its investment in Ascend Analytics
  • The Home Depot in its $18.25 billion acquisition of SRS Distribution Inc.
  • Iron Mountain in its acquisition of Regency Technologies
  • JPMorgan Chase, as lead arranger and administrative agent, in a $400 million senior secured revolving facility for Etsy Inc.
  • Kenect, LLC (a portfolio company of PSG) its acquisition of Friendemic Inc.
  • KIK Consumer Products (a portfolio company of Centerbridge Partners) in the sale of its Auto Care business to Recochem
  • The Kroger Company in its pending $24.6 billion merger with Albertsons Companies, Inc.
  • The Kroger Company, along with The Albertsons Companies, Inc., in the approximately $1.9 billion sale of 413 stores, as well as select banners, distribution centers, offices and private label brands, to C&S Wholesale Grocers, LLC in connection with Kroger’s proposed merger with Albertsons Companies Inc.
  • The Kroger Company in its pending sale of Kroger Specialty Pharmacy to CarelonRx Inc.
  • Main Event Entertainment, Inc. (a subsidiary of Ardent Leisure Group Limited in which RedBird Capital is a minority investor) in its $835 million sale to Dave & Buster’s, Inc.
  • MarketAxess Holdings Inc. in its acquisition of Pragma LLC
  • Quest Diagnostics Inc. in its $300 million acquisition of Haystack Oncology
  • Redbox Entertainment Inc. in its sale to Chicken Soup for the Soul Entertainment, Inc.
  • Reservoir Capital Group, LLC in sale of its majority stake in ClearCaptions LLC to CC Opportunities, LLC
  • Sanofi SA in its acquisition of Provention Bio Inc. for $2.9 billion in cash and its pending sale of Enjaymo®
  • SoftBank Group Corp. and SoftBank Vision Fund II in connection with WeWork’s chapter 11 cases with $3.8 billion in aggregate principal amount of funded debt
  • Warner Bros. Discovery, Inc. in its sale of AT&T SportsNet Southwest to Houston Astros and Houston Rockets

Grant is recognized for Tax Law by Best Lawyers: Ones to Watch in America 2024.

Grant received his LL.M., with distinction, from Georgetown University Law Center, where he made the Dean’s List and was a recipient of the CALI Award for Tax Planning for Corporate Acquisitions Seminar. He received his J.D. from Georgetown University Law Center, where he served as Senior Executive Editor of the Georgetown Immigration Law Journal, and his B.A., cum laude, from Harvard University, where he was a recipient of the Susan Anthony Potter Prize and the Ned Weld Above and Beyond Award. He is fluent in Spanish and Portuguese.

Awards and Recognition, Speaking Engagements, Guides and Resources, Latest Thinking, Firm News & Announcements

Latest Thinking

  • TREASURY AND IRS ISSUE FINAL RULES RELATING TO REPATRIATION OF IP Blog Post — Tax Blog — By Devon Bodoh, Greg Featherman and Grant Solomon — October 10, 2024
    On October 9, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations (the “Final Regulations”), which, in certain cases, terminate the continued application of Section 367(d) of the Internal Revenue Code (the “Code”) from a previous transfer of intangible property to a foreign corporation when the intangible property is repatriated to certain U.S. persons.Background.Section 367(d) of the Code provides rules for outbound transfers of intangible property (e.g., intellectual property) by a U.S. person (a “U.S. transferor”) to a foreign corporation. Under these rules, when a U.S. transferor transfers intangible property to a foreign corporation in an otherwise tax-free exchange under Sections[1] 351 or 361, the U.S. transferor is treated as having sold the intangible property in exchange for annual royalty payments (an “annual inclusion”) over the useful life of the intangible property (or a lump sum payment in the case of a disposition of the intangible property following the initial outbound transfer). The U.S. transferor treats the annual inclusion and lump sum as ordinary income and royalties for purposes of determining source and the foreign tax credit limitation category.On May 3, 2023, Treasury and the IRS published a notice of proposed rulemaking under Section 367 (the “Proposed Regulations”). The Proposed Regulations were intended to address simple, common fact patterns involving repatriations of intangible property by terminating the continued application of Section 367(d) when a transferee foreign corporation repatriates intangible property subject to Section 367(d) to a qualified domestic person when certain reporting requirements are satisfied. The Proposed Regulations also included a rule coordinating the application of Section 367(d) and the provisions in Treasury Regulations Section 1.904-4(f)(2)(vi)(D) that apply the principles of Section 367(d) to determine the appropriate amount of gross income attributable to a foreign branch.The Final Regulations adopt, without significant modification, the Proposed Regulations. For a further discussion of the proposed regulations, see “IP Phone Home – IRS Issues New Proposed Rules on the Repatriation of Intangible Property” posted on the Weil Tax Blog on May 4, 2023.Final Regulations.As indicated above, the Final Regulations adopted the Proposed Regulations with only minor changes. In addition to a clarification to one example, the Proposed Regulations clarify one aspect of the reporting rules. As a condition for terminating the application of Section 367(d) with respect to repatriated intangible property, the Proposed Regulations would have required a U.S. transferor to provide the information described in Proposed Treasury Regulations Section 1.6038B-1(d)(2)(iv). If a U.S. transferor failed to provide that information, the requirement to take an annual inclusion into account over the useful life of the intangible property, continued to apply. However, a U.S. transferor was eligible for relief under the Proposed Regulations if the Proposed Regulations would have applied to the subsequent transfer of intangible property but for the fact that the required information was not provided and the U.S. transferor, upon becoming aware of the failure, promptly provided the required information, explained its failure to comply, and met certain other requirements (if applicable).One comment to the Proposed Regulations requested that the Final Regulations clarify whether relief for a failure to comply is, in relevant part, also conditioned on the U.S. transferor timely filing one or more amended returns for the taxable year in which the subsequent transfer occurred and succeeding years, and, if the U.S. transferor is under examination when an amended return is filed, providing a copy of the amended return(s) to the IRS personnel conducting the examination. Treasury and the IRS adopted that comment in the Final Regulations to clarify that the relief for a failure to comply is conditioned upon the requirements listed in the previous sentence (if applicable).Applicability Date.Consistent with the applicability date in the Proposed Regulations, the Final Regulations apply only to repatriations of intangible property occurring on or after the date the final regulations are published in the Federal Register, which is scheduled to be October 10, 2024. ...
  • Treasury and IRS Issue Long Awaited Proposed Regulations on the Corporate Alternative Minimum Tax Blog Post — Tax Blog — By Devon Bodoh and Grant Solomon — September 16, 2024
    On September 12, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG 112129-23, RIN 1545-BQ84) (the “Proposed Regulations”) providing much needed guidance on the application of the corporate alternative minimum tax (“CAMT”). In addition to the Proposed Regulations, Treasury and the IRS also issued Notice 2024-66, which waives the penalty for a corporation’s failure to pay estimated tax with respect to its CAMT for a taxable year that begins after December 31, 2023, and before January 1, 2025. ...
  • Easy as ABC – IRS Issues Final Rules Aimed at Stymieing Killer Bs Blog Post — Tax Blog — By Devon Bodoh, Greg Featherman and Grant Solomon — July 18, 2024
    On July 17, 2024, the Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued final regulations under Section 367(b) of the Internal Revenue Code (the “Code”) that provide guidance applicable to: the treatment of property used to acquire parent stock or securities in connection with certain triangular reorganizations involving one or more foreign corporations; the consequences to persons that receive parent stock or securities pursuant to those reorganizations; and the treatment of certain subsequent inbound nonrecognition transactions following those reorganizations and certain other tax-free transactions (the “Final Regulations”). The Final Regulations adopt, without significant modification, the proposed regulations (published in the Federal Register on October 6, 2023) (the “Proposed Regulations”). ...
  • Final Regulations: Guidance on Reporting and Payment of Excise Tax Blog Post — Tax Blog — By Devon Bodoh and Grant Solomon — July 02, 2024

    On June 28, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) released final regulations (T.D. 10002) (the “Final Regulations”) that provide guidance applicable to the reporting and payment of the excise tax under section 4501 of the Internal Revenue Code of 1986, as amended (the “Code”), on repurchases of

    The post Final Regulations: Guidance on Reporting and Payment of Excise Tax appeared first on Weil Tax BLOG.

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  • Clear as Mud – Chevron Irreverence and Tax Law Blog Post — Tax Blog — By Devon Bodoh and Grant Solomon — July 01, 2024

    In a 6-3 decision written by Chief Justice Roberts, the Supreme Court in Loper Bright Enterprises v. Raimondo overturned the Court’s decision in Chevron v. Natural Resources Defense Council, 467 U.S. 837 (1984), and held that federal agency interpretations of law are not entitled to any deference (such as the deference provided to the Department

    The post Clear as Mud – Chevron Irreverence and Tax Law appeared first on Weil Tax BLOG.

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