Ryan Bray

Ryan Bray

Partner

Ryan advises clients on tax aspects of corporate and partnership transactions, with a particular focus on cross-border, mergers and acquisitions transactions, joint ventures and internal restructurings.
 Furthermore, Ryan regularly advises emerging growth companies and their founders in connection with choice-of-entity decisions, and qualified small business stock (QSBS) planning.

Experience

Representative matters

Mergers and Acquisitions

Fenway Sports Group in a variety of matters, including its sale of a minority interest in Liverpool FC to Dynasty Equity, its purchase of a controlling interest in Boston Common Golf, the extension of its partnership with LeBron James and sports executive Maverick Carter through an investment in LRMR Ventures LLC, its investment in GOAL (Green Operations & Advanced Leadership), its sale of the Salem Red Sox minor league baseball club to Diamond Baseball Holdings, its ownership of The Boston Red Sox, Pittsburg Penguins, Liverpool FC and New England Sports Network. 

Strategic Sports Group (SSG) in a partnership with the PGA TOUR to launch PGA TOUR Enterprises, a new commercial venture.

Paramount Global in multiple transactions, including its $1.62 billion sale of Simon & Schuster to KKR, its $500 million sale of CNET Media Group to Red Ventures, its sale of Bellator to the Professional Fighters League, its acquisition of AwesomenessTV Holdings, LLC, and multiple joint venture transactions.

Viacom Inc. in its $30 billion merger with CBS Corporation.

Celanese Corporation in its $11 billion acquisition of DuPont’s Mobility & Materials business, its sale of a 70% interest in its Nutrinova food ingredients business to Mitsui & Co., its restructuring of its 50/50 Korea Engineering Plastics Co. joint venture with Mitsubishi Gas Chemical Company, Inc., its $1.575 billion divestiture of its interest in its Polyplastics joint venture to Daicel Corporation and various other transactions.

Published Work

Lowther, T., Crouch, L., Bray, R., Emmett Moldowan, G., Aghai, I., Garg, J. 2023, “Tax Court Agrees Profits Interest Safe Harbor Should Apply to Tiered Partnership Structure”, Journal of Taxation of Investments

Qualifications

Admissions

California, 2011
Texas, 2019

Academic

B.A., Political Science, UC, Los Angeles, 2007
J.D., Pepperdine University, 2010, Journal of Business, Entrepreneurship & the Law
LL.M., Taxation, New York University, 2011

Disclaimer
A&O Shearman was formed on May 1, 2024 by the combination of Shearman & Sterling LLP and Allen & Overy LLP and their respective affiliates (the legacy firms). Any matters referred to above may include matters undertaken by one or more of the legacy firms rather than A&O Shearman.