Photo of Michael K. Marion
Michael K. Marion




As a partner in the Tax Transactions group, Michael focuses on advising clients on the tax aspects of a broad range of transactions, including structured and leveraged finance transactions, capital markets transactions and securitizations (including CLO transactions), as well as taxable and nontaxable mergers and acquisitions. He also regularly advises clients on international, corporate and consolidated return tax issues as well as financial products, FATCA and derivatives (including ISDA documentation).


  • Englisch


  • Represented domestic mortgage servicing company in multi-tranche servicer advance securitization with a note principal balance of +$1 billion.
  • Represented Canadian financial institution in excess loss note (ELN) take out restructuring for its U.S. commercial paper conduit.
  • Represented leading global asset manager in multiple CLO transactions with note principal balances of +$1 billion, including representation of CLO issuer.
  • Represented global financial institution in $400 million regulatory capital hybrid security issuance involving Asia, Australia and the United States.
  • Represented lender in multiple asset-based railcar securitizations with note principal balances of +$1 billion.
  • Represented international private equity fund in +$150 million leveraged stock acquisition of chemical business, including negotiation of tax-related acquisition financing terms.
  • Represented purchaser in $350 million stock acquisition of construction business treated as an asset acquisition under Code section 338(h)(10).
  • Represented global financial institution in multiple cross-border tax-free spin-offs.
  • Represented global financial institution in obtaining private letter rulings relating to the application of the consolidated return regulations and Code section 382, respectively.
  • Represented Canadian global financial institution in a tax-free internal restructuring of its U.S. business, relating to the integration of new and legacy businesses.
  • Represented global financial institution as lender and administrative agent in +$600 million credit facility that included a term loan, revolving loan and a letter of credit.
  • Represented borrower in $240 million multi-jurisdictional borrowing, including issues related to security package and Code section 956 issues.


New York University School of Law , LLM

The George Washington University Law School, JD, with honors

University of Michigan, BA, in Psychology


  • New York