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Lawyers

Brian Grieve

Lawyers

Advises alternative asset managers on a wide range of tax issues arising in the formation, structuring and ongoing operation of U.S. and non-U.S. investment vehicles.

Brian advises alternative asset managers on a wide range of tax issues arising in the formation, structuring and ongoing operation of U.S. and non-U.S. investment vehicles. His practice includes private equity, credit, hybrid capital and special situations funds, as well as real estate and infrastructure funds, and the tax-efficient structuring of investments made by those funds.

He also counsels private equity sponsors and corporate clients on the tax aspects of complex transactions, including public and private mergers and acquisitions, strategic investments, joint ventures and bankruptcy-related and other restructuring matters. Brian also has significant experience in financing and capital markets transactions, including structured finance and securitizations, and regularly advises on tax issues involving derivative products.

Brian has been recognized by International Tax Review as a “Tax Rising Star” and recently was named one of “500 Leading Global Tax Lawyers” by Lawdragon.

Experience

Brian’s representations prior to joining Davis Polk include:

Fund Formation & Investment Management
  • Apollo in the:
    • launch of Apollo Sports Capital
    • formation of a first-of-its-kind $25 billion private credit, direct lending program between affiliates of Apollo and Citigroup
    • formation of Apollo Origination Partnership II, a $4.8 billion credit fund
    • formation of its Sponsor and Secondary Solutions business, a dedicated secondary and fund finance capital solutions platform totaling $5 billion
    • formation of its Accord and Accord+ strategy of dislocation credit funds, totaling $8.5 billion
    • formation of the $20 billion Apollo Investment Fund X
    • formation of the $4.6 billion Apollo Hybrid Value Fund II
    • formation of the $2.4 billion Apollo Infrastructure Opportunities Fund III
  • Blackstone Alternative Asset Management in connection with numerous investment transactions and fund formation matters
  • Oak Hill Advisors in the formation of investment funds including:
    • OHA Senior Private Lending Fund, its flagship evergreen direct lending strategy with $17.7 billion of available capital, including $8 billion of equity commitments
    • the $2.3 billion OHA Strategic Credit Fund III
    • the $1.1 billion OHA CLO Enhanced Equity Fund III
Mergers & Acquisitions
  • Apollo in the:
    • acquisition of Bridge Investment Group in an all-stock transaction
    • $8 billion acquisition of Credit Suisse’s assets from UBS
    • $11 billion merger with Athene
    • acquisition of an 80.1% interest in Lumileds from Royal Philips, in a transaction with an enterprise value of approximately $2 billion
    • acquisition of Shutterfly and Snapfish, with the Shutterfly transaction valued at $2.7 billion
  • Virtu Financial in transactions including:
    • its approximately $1.4 billion all-cash acquisition of KCG Holdings
    • its approximately $1 billion acquisition of Investment Technology Group
Hybrid Capital
  • Apollo in transactions including:
    • alongside ATLAS SP Partners, a $5 billion strategic financing collaboration with BNP Paribas
    • a $6.5 billion joint bid alongside Knighthead Capital Management and Certares Opportunities as sponsor to Hertz Global Holdings’ chapter 11 plan of reorganization
    • commitments in respect of a $2.5 billion preferred equity issuance to support the acquisition of Citrix by affiliates of Vista Equity Partners and Evergreen Coast Capital
    • as lead investors, the $1.75 billion preferred investment in Albertsons

Recognition

International Tax Review – “Tax Rising Star,” 2023

Lawdragon – “500 Leading Global Tax Lawyers”

Education

J.D., Georgetown University Law Center
  • cum laude
B.A., Boston College
  • magna cum laude

Prior experience

  • Partner, Paul, Weiss, Rifkind, Wharton & Garrison, 2018-2026
  • Associate, Paul, Weiss, Rifkind, Wharton & Garrison, 2009-2017

Qualifications and admissions

  • State of New York
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