Nicole L. Greenblatt, P.C. Whitney Fogelberg (pro hac vice ... · Nicole L. Greenblatt, P.C....
Transcript of Nicole L. Greenblatt, P.C. Whitney Fogelberg (pro hac vice ... · Nicole L. Greenblatt, P.C....
Nicole L. Greenblatt, P.C. Whitney Fogelberg (pro hac vice pending)Susan D. Golden KIRKLAND & ELLIS LLPKIRKLAND & ELLIS LLP KIRKLAND & ELLIS INTERNATIONAL LLPKIRKLAND & ELLIS INTERNATIONAL LLP 300 North LaSalle Street601 Lexington Avenue Chicago, Illinois 60654New York, New York 10022 Telephone: (312) 862-2000Telephone: (212) 446-4800 Facsimile: (312) 862-2200Facsimile: (212) 446-4900
Proposed Counsel to the Debtors and Debtors in Possession
UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF NEW YORK
)In re: ) Chapter 11
)LAKELAND TOURS, LLC, et al.,1 ) Case No. 20-11647 (___)
)Debtors. ) (Joint Administration Requested)
)
DEBTORS’ MOTION FOR ENTRY OF INTERIM AND FINAL
ORDERS (I) AUTHORIZING THE PAYMENT OF CERTAIN PREPETITION TAXES AND FEES AND (II) GRANTING RELATED RELIEF
The above-captioned debtors and debtors in possession (collectively, the “Debtors”)
respectfully state as follows in support of this motion (this “Motion”):2
Relief Requested
1. The Debtors seek entry of interim and final orders, substantially in the forms
attached hereto as Exhibit A and Exhibit B (respectively, the “Interim Order” and “Final Order”),
(a) authorizing the Debtors to negotiate, remit, and pay (or use applicable credits or overpayments
1 A complete list of each of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’ proposed claims and noticing agent at https://cases.stretto.com/WorldStrides. The location of the Debtors’ service address in these chapter 11 cases is: 49 West 45th Street, New York, NY 10036.
2 A detailed description of the Debtors and their business, and the facts and circumstances supporting this Motion are set forth in the Declaration of Kellie Goldstein, Chief Financial Officer of Lakeland Tours, LLC d/b/a WorldStrides, (I) In Support of Chapter 11 Petitions and First Day Pleadings and (II) Pursuant to Local Bankruptcy Rule 1107-2 (the “First Day Declaration”), filed contemporaneously with the commencement of these chapter 11 cases and incorporated by reference herein.
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to offset) certain accrued and outstanding prepetition obligations accrued in the ordinary course of
business on account of the Taxes and Fees (as defined herein), including those obligations
subsequently determined upon audit or otherwise to be owed for periods prior to the Petition Date;
(b) authorizing the Debtors to continue paying the Taxes and Fees accrued in the ordinary course
of business on a postpetition basis; and (c) granting related relief. In addition, the Debtors request
that the Bankruptcy Court schedule a final hearing to consider approval of this Motion on a final
basis.
Jurisdiction and Venue
2. The United States Bankruptcy Court for the Southern District of New York
(the “Bankruptcy Court”) has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334
and the Amended Standing Order of Reference from the United States District Court for the
Southern District of New York, dated January 31, 2012. The Debtors confirm their consent,
pursuant to rule 7008 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), to
the entry of a final order by the Bankruptcy Court in connection with this Motion to the extent that
it is later determined that the Bankruptcy Court, absent consent of the parties, cannot enter final
orders or judgments in connection herewith consistent with Article III of the United States
Constitution.
3. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.
4. The bases for the relief requested herein are sections 105(a), 363(b), 507(a)(8), and
541 of title 11 of the United States Code (the “Bankruptcy Code”), Bankruptcy Rules 6003 and
6004, and Rule 9013-1(a) of the Local Bankruptcy Rules for the Southern District of
New York (the “Local Rules”).
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Background
5. The Debtors, together with their non-Debtor affiliates, provide full-service
educational travel and experiential learning programs domestically and internationally for students
from K12 to graduate level. The Debtors are the United States’ largest accredited travel company,
providing organized educational travel and other experiential learning programs for more than
550,000 students in 2019. The Debtors generated approximately $650 million in net revenue in
fiscal year 2019, and employ approximately 1,500 people domestically and internationally. The
Debtors have historically enjoyed a stable position as the preeminent provider of educational
travel. However, the Debtors’ businesses have sustained significant losses as a result of the
worldwide shutdown of travel due to the COVID-19 pandemic, with additional constraints to
liquidity anticipated in August and September 2020 as the Debtors continue to provide customer
refunds. As of July 20, 2020, (the “Petition Date”), the Debtors have approximately $768 million
in funded debt obligations.
6. Prior to the Petition Date, the Debtors entered into a restructuring support
agreement (the “Restructuring Support Agreement”) with their key stakeholders, including
approximately 85% of the holders of the Debtors’ senior secured credit facility, their consenting
hedge provider J. Aron & Company, and their sponsors, Eurazeo North America and Primavera
Capital Management Ltd. (the “Sponsors”), and launched solicitation of a prepackaged plan of
reorganization (the “Plan”). The Debtors have commenced these chapter 11 cases to effectuate
the transactions contemplated in the Restructuring Support Agreement and the Plan to restructure
their funded debt, while ensuring that the financial restructuring will have a minimal impact on the
Debtors’ operations, their key business partners, and their customers.
7. On the Petition Date, each of the Debtors filed a voluntary petition for relief under
chapter 11 of the Bankruptcy Code. The Debtors are operating their businesses and managing
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their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the
Bankruptcy Code. Concurrently with the filing of this Motion, the Debtors have requested
procedural consolidation and joint administration of these chapter 11 cases pursuant to
Bankruptcy Rule 1015(b).
The Debtors’ Tax and Fee Obligations
I. Overview of the Debtors’ Tax and Fee Obligations.
8. In the ordinary course of business, the Debtors collect, incur, remit, withhold,
and/or pay income taxes, sales taxes, use taxes, franchise taxes, gross receipt taxes, withholding
taxes, payroll taxes, annual report and licensing fees, property taxes, and other taxes, fees, fines,
penalties, assessments and similar charges (collectively, the “Taxes and Fees”).3 The Debtors
remit and/or pay the Taxes and Fees to various federal, state, and local governments, including
taxing and licensing authorities on a monthly, quarterly, or annual basis depending on the nature
and incurrence of a particular Tax or Fee (collectively, the “Authorities”). A schedule identifying
the Authorities is attached hereto as Exhibit C.4 Taxes and Fees are remitted and paid by the
Debtors through checks and electronic transfers that are processed through their banks and other
financial institutions. From time to time, the Debtors also receive tax credits for overpayments or
refunds in respect of Taxes and Fees. The Debtors use these credits in the ordinary course of
business to offset against future Taxes and Fees or have such amounts refunded to the Debtors.
3 By this motion, the Debtors do not seek the authority to collect and remit state and federal employee-related withholding taxes. Such relief is instead requested in the Debtors’ Motion Seeking Entry of an Order (I) Authorizing, But Not Directing, the Debtors to (A) Pay Prepetition Employee Wages, Salaries, Other Compensation, and Reimbursable Employee Expenses and (B) Continue Employee Benefits Programs and (II) Granting Related Relief, filed contemporaneously herewith.
4 Although Exhibit C is intended to be comprehensive, the Debtors may have inadvertently omitted one or more Authorities. By this motion, the Debtors request relief applicable to all Authorities, regardless of whether such Authority is specifically identified on Exhibit C.
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9. The Debtors estimate that approximately $13,900.00 in Taxes and Fees relating to
the prepetition period (including so-called “straddle” periods)5 are or will become due and owing
to the Authorities after the Petition Date in the ordinary course, in connection with audits, or in
connection with resolutions or statutory “amnesty” provisions. The Debtors estimate that no
Taxes and Fees relating to the prepetition period are or will become due and owing to the
Authorities within the first 30 days of these chapter 11 cases.6 However, out of an abundance of
caution, the Debtors seek authority, but not direction, to pay any amounts that come due.7
10. The following table contains descriptions of the Taxes and Fees, as well as
the Debtors’ estimate of the amounts of the Taxes and Fees accrued as of the Petition Date:
Category Description
Approximate Amount Accrued as of Petition Date
Approximate Amount Due
within 30 days
Sales and Use Taxes
The Debtors collect and remit sales, use, and related taxes to the Authorities in various states (the “Sales and Use Taxes”).
$13,200.00 $0
5 Claims for so-called “straddle” Taxes and Fees may be entitled to administrative claim treatment pursuant to section 503(b)(1)(B) of the Bankruptcy Code. A recent Delaware bankruptcy court decision held that the portion of a “straddle” tax claim that is attributable to the prepetition portion of a “straddle” period is not entitled to administrative priority and, in fact, is not entitled to priority under section 507(a)(8)(A) of the Bankruptcy Code. See In re Affirmative Ins. Holdings, Inc., 607 B.R. 175, 188 (Bankr. D. Del. 2019). Because the Debtors could be subject to late payment penalties and interest in the event they do not pay such “straddle” Taxes and Fees and a court ultimately concludes that such taxes are entitled to administrative treatment, the Debtors are seeking the authority to pay such “straddle” Taxes and Fees as they become due under applicable law. The Debtors reserve their rights with respect to the proper characterization of such “straddle” Taxes and Fees and to seek reimbursement of any portion of a payment that was made that ultimately is not entitled to administrative or priority treatment.
6 Contemporaneously with the filing of this Motion, the Debtors have filed certain other “first day” motions seeking authority to satisfy certain prepetition claims. As used herein, “Taxes and Fees” does not include any of the obligations the Debtors seek to pay under a separate motion. Nothing contained herein is intended or should be construed as an admission as to the validity of any claim against the Debtors or a waiver of the Debtors’ rights to dispute any asserted claim.
7 This estimate does not include any potential prepetition tax liability that may later come due as the result (or conclusion) of any pending or future audits. For the avoidance of doubt, the Debtors seek authority, but not direction, to pay any amounts that later come due as the result (or conclusion) of any pending or future audits in connection with their Taxes and Fees to avoid material disruptions to the Debtors’ business operations.
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Category Description
Approximate Amount Accrued as of Petition Date
Approximate Amount Due
within 30 days
Property Taxes The Debtors remit property taxes directly to the Authorities relating to personal and real property that the Debtors use in the operation of their businesses, whether owned or leased (the “Property Taxes”).
$700.00 $0
Total $13,900.00 $0
II. Key Tax Considerations.
11. The Debtors believe that failing to pay the Taxes and Fees could materially disrupt
the Debtors’ business operations in several ways, including that: (a) the Authorities may initiate
audits, suspend operations, file liens, seek to lift the automatic stay, and pursue other remedies that
would harm the estate, which would unnecessarily divert the Debtors’ attention from the
reorganization process; (b) failing to pay Taxes and Fees could subject certain of the Debtors’
directors and officers to claims of personal liability, which would distract those key employees
from their duties related to the Debtors’ restructuring; (c) failing to pay certain of the Taxes and
Fees likely could cause the Debtors to lose their ability to conduct business in certain jurisdictions;
and (d) unpaid Taxes and Fees may result in penalties, the accrual of interest, or both, any of which
could negatively impact the Debtors’ businesses or the reorganization process.
12. In addition, the Debtors collect and hold certain outstanding tax liabilities in trust
for the benefit of the applicable Authorities, and these funds may not constitute property of
the Debtors’ estates.
Basis for Relief
I. Certain of the Taxes and Fees are Not Property of the Debtors’ Estates.
13. The Debtors have held in trust and, thus, collected or withheld certain of the Taxes
and Fees on behalf of the applicable Authorities and held such amounts in trust on behalf of the
applicable Authorities. See, e.g., I.R.C. § 7501 (stating that certain taxes and fees are held in
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trust). As such, these Taxes and Fees are not property of the Debtors’ estates under section 541 of
the Bankruptcy Code. See, e.g., 11 U.S.C. § 541(d); Begier v. IRS, 496 U.S. 53, 57-60 (1990)
(holding that any prepetition payment of trust fund taxes is not an avoidable preference because
the funds are not the debtor’s property); DeChiaro v. N.Y. State Tax Comm’n, 760 F.2d 432,
435-36 (2d Cir. 1985) (same). To the extent these “trust fund” taxes are collected, they are not
property of the Debtors’ estates under section 541(d) of the Bankruptcy Code. See, e.g.,
I.R.C. § 7501 (stating that certain taxes and fees are held in trust); In re Rodriguez, 50 B.R. 576,
580 (Bankr. E.D.N.Y. 1985); see also In re Am. Int’l Airways, Inc., 70 B.R. 102, 104–05 (Bankr.
E.D. Pa. 1987). Because the Debtors do not have an equitable interest in any of the “trust fund”
Taxes and Fees held on account of the Authorities, the Debtors should be permitted to pay those
funds to the Authorities as they become due in the ordinary course of business on a postpetition
basis.8
II. Payment of the Taxes and Fees as Provided Herein Is a Sound Exercise of the Debtors’ Business Judgment.
14. Courts in this jurisdiction generally acknowledge that it is appropriate to authorize
the payment of prepetition obligations where necessary to protect and preserve the estate,
including an operating business’s going-concern value. See In re Ionosphere Clubs, Inc., 98 B.R.
174, 175 (Bankr. S.D.N.Y. 1989) (affirming lower court order authorizing payment of prepetition
wages pursuant to section 363(b) of the Bankruptcy Code); Armstrong World Indus., Inc. v. James
A. Phillips, Inc. (In re James A. Phillips, Inc.), 29 B.R. 391, 398 (S.D.N.Y. 1983) (granting
authority to pay prepetition claims of suppliers); accord In re CoServ, L.L.C., 273 B.R. 487, 497
(Bankr. N.D. Tex. 2002). In doing so, these courts acknowledge that several legal theories rooted
8 For the avoidance of doubt, the Debtors hereby request authority to pay, in their sole discretion, the Taxes and Fees as provided herein regardless of whether such Taxes and Fees constitute trust fund obligations.
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in sections 105(a) and 363(b) of the Bankruptcy Code support the payment of prepetition claims
as provided herein.
15. Pursuant to section 363(b) of the Bankruptcy Code, courts may authorize payment
of prepetition obligations where a sound business purpose exists for doing so. See Ionosphere
Clubs, 98 B.R. at 175 (noting that section 363(b) of the Bankruptcy Code provides “broad
flexibility” to authorize a debtor to honor prepetition claims where supported by an appropriate
business justification); see also James A. Phillips, Inc., 29 B.R. at 397 (relying upon section 363
of the Bankruptcy Code as a basis to allow a contractor to pay the prepetition claims of suppliers
who were potential lien claimants). Indeed, courts have recognized that there are instances when
a debtor’s fiduciary duty can “only be fulfilled by the pre-plan satisfaction of a prepetition claim.”
CoServ, 273 B.R. at 497.
16. In addition, courts may authorize payment of prepetition claims in appropriate
circumstances based on section 105(a) of the Bankruptcy Code, which codifies the Bankruptcy
Court’s inherent equitable powers to “issue any order, process, or judgment that is necessary or
appropriate to carry out the provisions of this title.” Under section 105(a) of the Bankruptcy Code,
courts may authorize preplan payments of prepetition obligations when essential to the continued
operation of a debtor’s business. See In re C.A.F. Bindery, Inc., 199 B.R. 828, 835
(Bankr. S.D.N.Y. 1996); see also In re Fin. News Network Inc., 134 B.R. 732, 735–36
(Bankr. S.D.N.Y. 1991) (holding that the “doctrine of necessity” stands for the principle that a
bankruptcy court may allow preplan payments of prepetition obligations where such payments are
critical to the debtor’s reorganization). Specifically, the Bankruptcy Court may use its power
under section 105(a) of the Bankruptcy Code to authorize payment of prepetition obligations
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pursuant to the “necessity of payment” rule (also referred to as the “doctrine of necessity”).
Ionosphere Clubs, 98 B.R. at 176.
17. Several courts apply the doctrine of necessity where payment of a prepetition claim
(a) is “necessary for the successful reorganization of the debtor,” (b) falls within “the sound
business judgment of the debtor,” and (c) will not “prejudice other unsecured creditors.”
In re United Am. Inc., 327 B.R. 776, 782 (Bankr. E.D. Va. 2005); see also Ionosphere Clubs,
98 B.R. at 176. A bankruptcy court’s use of its equitable powers to “authorize the payment of
pre-petition debt when such payment is needed to facilitate the rehabilitation of the debtor is not a
novel concept.” See Ionosphere Clubs, Inc., 98 B.R. at 175. That is because the rehabilitation of
a debtor in reorganization cases remains “the paramount policy and goal of Chapter 11.” Id. at
175–76; see also In re Just For Feet, 242 B.R. 821, 826 (D. Del. 1999) (finding that payment of
prepetition claims to certain trade vendors was “essential to the survival of the debtor during the
chapter 11 reorganization”).
18. Implicit in the fiduciary duties of any debtor in possession is the obligation to
“protect and preserve the estate, including an operating business’s going concern value.”
See also CoServ, 273 B.R. at 497. Some courts note that there are instances in which a debtor can
fulfill this fiduciary duty “only . . . by the preplan satisfaction of a prepetition claim.” Id. The
court in CoServ specifically noted the pre-plan satisfaction of prepetition claims would be a valid
exercise of the debtor’s fiduciary duty when the payment “is the only means to effect a substantial
enhancement of the estate . . . .” Id. Consistent with a debtor’s fiduciary duties, courts have also
authorized payment of prepetition obligations under section 363(b) of the Bankruptcy Code where
a sound business purpose exists for doing so. See Ionosphere Clubs, 98 B.R. at 175.
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19. These standards are satisfied here. The Debtors’ ability to pay the Taxes and Fees
is critical to their continued and uninterrupted operations and maintaining the efficient and value-
maximizing administration of the Debtors’ estates. If certain Taxes and Fees remain unpaid,
certain Authorities may seek to impose penalties on, or recover such amounts directly from, the
Debtors’ directors, officers, and/or employees, thereby distracting them from the administration of
the Debtors’ chapter 11 cases. See, e.g., N.Y. Tax Law § 1133 (“[E]very person required to collect
any tax imposed by this article shall be personally liable for the tax imposed, collected or required
to be collected under this article.”); In re Am. Motor Club, Inc., 139 B.R. 578, 581–83 (Bankr.
E.D.N.Y. 1992) (stating “[i]f the employer fails to pay over the trust fund taxes, the IRS may
collect an equivalent amount directly from officers or employees of the employer who are
responsible for collecting the tax” and finding a director personally liable for unpaid taxes (citing
United States v. Energy Res. Co., 495 U.S. 545, 547 (1990))). Any collection action on account
of such penalties, and any ensuing liability, would distract the Debtors and their personnel to the
detriment of all parties in interest. The dedicated and active participation of the Debtors’ officers
and employees is integral to the Debtors’ continued operations and essential to the orderly
administration of these chapter 11 cases and maximizing the value of the Debtors’ estates for the
benefit of their stakeholders.
20. Furthermore, the Debtors’ inability to timely pay the Taxes and Fees may ultimately
result in increased tax liability for the Debtors if interest and penalties accrue on account of such
Taxes and Fees. Many of the Taxes and Fees may be entitled to priority claims, pursuant to
section 507(a)(8)(C) of the Bankruptcy Code, which must be paid in full in cash before any general
unsecured obligations may be satisfied. Thus, the Debtors’ failure to pay the prepetition Taxes
and Fees as they come due may ultimately increase the amount of priority claims held by the
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Authorities against the Debtors’ estates to the detriment of the Debtors’ general unsecured
creditors and other stakeholders. See 11 U.S.C. § 507(a)(8)(C), (G). Accordingly, the Bankruptcy
Court should grant the Debtors’ authority to pay, in their sole discretion, the prepetition Taxes and
Fees as provided herein.
21. Bankruptcy courts in this jurisdiction have often authorized payment of prepetition
taxes under section 363(b) of the Bankruptcy Code. See, e.g., In re Frontier Commc’ns. Corp.,
No. 20-22476 (RDD) (Bankr. S.D.N.Y. May 26, 2020) (authorizing debtors to pay prepetition
taxes); In re Deluxe Entm’t Servs. Grp. Inc., No. 19-23774 (RDD) (Bankr. S.D.N.Y. Oct. 25, 2019)
(same); In re Hollander Sleep Prods., LLC, No. 19-11608 (MEW) (Bankr. S.D.N.Y. July 2, 2019)
(same); In re Sungard Availability Servs. Capital, Inc., No. 19-22915 (RDD) (Bankr. S.D.N.Y.
May 2, 2019) (same); In re Windstream Holdings, Inc., No. 19-22312 (RDD) (Bankr. S.D.N.Y.
Feb. 28, 2019) (same).9
Processing of Checks and Electronic Fund Transfers Should Be Authorized
22. The Debtors expect to have sufficient funds to pay the amounts described in this
Motion in the ordinary course of business by virtue of expected cash flows from ongoing business
operations and anticipated access to debtor in possession financing. In addition, under the
Debtors’ existing cash management system, the Debtors can readily identify checks or wire
transfer requests as relating to an authorized payment in respect of the relief requested herein.
Accordingly, the Debtors believe there is minimal risk that checks or wire transfer requests that
the Bankruptcy Court has not authorized will be inadvertently made. Therefore, the Debtors
respectfully request that the Bankruptcy Court authorize and direct all applicable financial
9 Because of the voluminous nature of the orders cited herein, such orders have not been attached to this Motion. Copies of these orders are available upon request to the Debtors’ proposed counsel.
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institutions, when requested by the Debtors, to receive, process, honor, and pay any and all checks
or wire transfer requests in respect of the relief requested in this Motion.
The Requirements of Bankruptcy Rule 6003 Are Satisfied10
23. Bankruptcy Rule 6003 empowers a court to grant relief within the first 21 days after
the Petition Date “to the extent that relief is necessary to avoid immediate and irreparable harm.”
As set forth in this Motion, the Debtors believe an immediate and orderly transition into chapter 11
is critical to the viability of their operations and that any delay in granting the relief requested
could hinder the Debtors’ operations and cause irreparable harm. Furthermore, the failure to
receive the requested relief during the first 21 days of these chapter 11 cases would severely disrupt
the Debtors’ operations at this critical juncture and imperil the debtor’s restructuring. Accordingly,
the Debtors submit that it has satisfied the “immediate and irreparable harm” standard of
Bankruptcy Rule 6003 to support granting the relief requested herein.
Waiver of Bankruptcy Rules 6004(a) and 6004(h)
24. To successfully implement the foregoing, the Debtors request that the Bankruptcy
Court enter an order providing that notice of the relief requested herein satisfies Bankruptcy Rule
6004(a) and that the Debtors have established cause to exclude such relief from the 14-day stay
period under Bankruptcy Rule 6004(h).
Reservation of Rights
25. Nothing contained in this Motion or any actions taken pursuant to any order
granting the relief requested by this Motion is intended or should be construed as (a) an admission
10 As more fully detailed in the Combined Hearing Motion, the Debtors are requesting a Combined Hearing within 30 days of the Petition Date, and the Debtors anticipate a final hearing on the Motion to be held on the same day as the Combined Hearing. Accordingly, the Debtors request relief within the first 30 days rather than the first 21 days under Bankruptcy Rule 6003.
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as to the amount of, basis for, or validity of any particular claim against the Debtors, (b) a waiver
of the Debtors’ rights to dispute any particular claim on any grounds, (c) a promise or requirement
to pay any particular claim, (d) an implication or admission that any particular claim is of a type
specified or defined in this Motion or any order granting the relief requested by this Motion, (e) a
request or authorization to assume any agreement, contract, or lease pursuant to section 365 of the
Bankruptcy Code, (f) a waiver or limitation of the Debtors’ rights under the Bankruptcy Code or
any other applicable law, [(g) an admission as to the validity, priority enforceability, or perfection
of any lien on, security interest in, or other encumbrance on property of the Debtors’ estates], or
(h) a concession by the Debtors that any liens (contractual, common law, statutory, or otherwise)
satisfied pursuant to this Motion are valid, and the Debtors expressly reserve their rights to contest
the extent, validity, or perfection or seek avoidance of all such liens. If the Bankruptcy Court
grants the relief sought herein, any payment made pursuant to the Bankruptcy Court’s order is not
intended and should not be construed as an admission as to the validity of any particular claim or
a waiver of the Debtors’ rights to subsequently dispute such claim.
Motion Practice
26. This Motion includes citations to the applicable rules and statutory authorities upon
which the relief requested herein is predicated and a discussion of its application to this Motion.
Accordingly, the Debtors submit that this Motion satisfies Local Rule 9013-1(a).
Notice
1. The Debtors will provide notice of this Motion to: (a) the United States Trustee for
the Southern District of New York, Attn: Benjamin J. Higgins; (b) the holders of the 50 largest
unsecured claims against the Debtors (on a consolidated basis); (c) counsel to the administrative
agent under the Debtors’ prepetition credit agreement, Latham and Watkins, LLP, 885 Third
Avenue, New York, NY 10022, Attn: Adam J. Goldberg and Hugh Murtagh; (d) counsel to the
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Sponsors, Cravath, Swaine & Moore LLP, Worldwide Plaza, 825 Eighth Avenue, New York, NY
10019, Attn: Paul H. Zumbro and George E. Zobitz, and Simpson Thacher & Bartlett LLP, 425
Lexington Avenue, New York, NY 10017, Attn: Michael H. Torkin; (e) counsel to the ad hoc
group of Consenting Lenders, Gibson, Dunn & Crutcher LLP, 200 Park Avenue, New York, NY
10166, Attn: Scott J. Greenberg, Steven A. Domanowski and Jeremy Evans; (f) the United States
Attorney’s Office for the Southern District of New York; (g) the Internal Revenue Service; (h) the
United States Securities and Exchange Commission; (i) the office of the attorney general in the
states where the Debtors conduct their business operations; and (j) any party that has requested
notice pursuant to Bankruptcy Rule 2002. The Debtors submit that, in light of the nature of the
relief requested, no other or further notice need be given.
No Prior Request
2. No prior request for the relief sought in this Motion has been made to this or any
other court.
[Remainder of page intentionally left blank]
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WHEREFORE, the Debtors respectfully request that the Bankruptcy Court enter the
Interim Order and Final Order granting the relief requested herein and such other relief as the
Bankruptcy Court deems appropriate under the circumstances.
Dated: July 21, 2020 /s/ Nicole L. GreenblattNew York, New York Nicole L. Greenblatt, P.C.
Susan D. GoldenKIRKLAND & ELLIS LLPKIRKLAND & ELLIS INTERNATIONAL LLP601 Lexington AvenueNew York, New York 10022Telephone: (212) 446-4800Facsimile: (212) 446-4900- and - Whitney Fogelberg (pro hac vice pending)KIRKLAND & ELLIS LLPKIRKLAND & ELLIS INTERNATIONAL LLP300 North LaSalle StreetChicago, Illinois 60654Telephone: (312) 862-2000Facsimile: (312) 862-2200
Proposed Counsel to the Debtors and Debtors in Possession
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EXHIBIT A
Proposed Interim Order
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UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF NEW YORK
)In re: ) Chapter 11
)LAKELAND TOURS, LLC, et al.,1 ) Case No. 20-11647 (___)
)Debtors. ) (Joint Administration Requested)
)
INTERIM ORDER (I) AUTHORIZING THE PAYMENT OF CERTAIN PREPETITION TAXES AND FEES AND (II) GRANTING RELATED RELIEF
Upon the motion (the “Motion”)2 of the above-captioned debtors and debtors in possession
(collectively, the “Debtors”) for entry of an interim order (this “Interim Order”), (a) authorizing
the Debtors to negotiate, remit, and pay (or use tax credits or overpayments to offset) certain
accrued and outstanding prepetition obligations accrued in the ordinary course of business on
account of the Taxes and Fees (as defined herein); and (b) granting related relief, all as more fully
set forth in the Motion; and upon the First Day Declaration; and this Bankruptcy Court having
jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334 and the Amended Standing
Order of Reference from the United States District Court for the Southern District of New York,
dated January 31, 2012; and this Bankruptcy Court having found that venue of this proceeding and
the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and this Bankruptcy
Court having found that the Debtors’ notice of the Motion and opportunity for a hearing on the
Motion were appropriate under the circumstances and no other notice need be provided; and this
Bankruptcy Court having reviewed the Motion and having heard the statements in support of the
1 A complete list of each of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’ proposed claims and noticing agent at https://cases.stretto.com/WorldStrides. The location of the Debtors’ service address in these chapter 11 cases is: 49 West 45th Street, New York, NY 10036.
2 Capitalized terms used but not defined herein have the meanings given to such terms in the Motion.
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2
relief requested therein at a hearing before this Bankruptcy Court (the “Hearing”); and this
Bankruptcy Court having determined that the legal and factual bases set forth in the Motion and at
the Hearing establish just cause for the relief granted herein; and upon all of the proceedings had
before this Bankruptcy Court; and after due deliberation and sufficient cause appearing therefor,
it is HEREBY ORDERED THAT:
1. The Motion is granted on an interim basis as set forth herein.
2. The final hearing (the “Final Hearing”) on the Motion shall be held on _________,
2020, at__:__ _.m., prevailing Eastern Time. Any objections or responses to entry of a final order
on the Motion shall be filed, with an e-mail copy to the Bankruptcy Court’s chambers, on or before
4:00 p.m., prevailing Eastern Time, on _________, 2020, in a manner consistent with the Case
Management Procedures. In the event no objections to entry of the Final Order on the Motion are
timely received, this Bankruptcy Court may enter such Final Order without need for the Final
Hearing.
3. The Debtors are authorized in their sole discretion to: (a) negotiate, pay or remit
(or use applicable credits or overpayments to offset) the obligations that arose or accrued in the
ordinary course of business on account of the Taxes and Fees prior to the Petition Date and that
will become due and owing (including, for the avoidance of doubt, as a result of the resolution of
any Audit) prior to entry of the Final Order and (b) negotiate, pay or remit Taxes and Fees that
arise or accrue in the ordinary course of business on a postpetition basis (including, for the
avoidance of doubt, as a result of the resolution of any Audit); provided, that in the event the
Debtors make a payment with respect to any Taxes and Fees for the prepetition portion of any
“straddle” amount and this Bankruptcy Court subsequently determines such amount was not
entitled to priority or administrative treatment under section 507(a)(8) or 503(b)(1)(B) of the
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3
Bankruptcy Code, the Debtors may (but shall not be required to) seek an order from the Bankruptcy
Court requiring a return of such amounts and the payment of such amount shall, upon order of the
Bankruptcy Court, be refunded to the Debtors. Notwithstanding the relief granted herein or any
actions taken hereunder, nothing contained in this Interim Order shall create any rights in favor of,
or enhance the status of any claim held by, any of the Authorities.
4. To the extent that the Debtors have overpaid any Tax or Fee, the Debtors are
authorized to seek a refund or credit.
5. Nothing in this Interim Order authorizes the Debtors to accelerate any payments
not otherwise due prior to the date of the Final Hearing, and the Debtors are only authorized under
this Interim Order to pay amounts that are due and owing prior to the date of the Final Hearing.
6. The Debtors are authorized to pay any amounts that later come due as the result (or
conclusion) of any pending or future audits in connection with their Taxes and Fees in the ordinary
course of business.
7. Notwithstanding the relief granted in this Interim Order and any actions taken
pursuant to such relief, nothing in this Interim Order shall be deemed: (a) an admission as to the
amount of, basis for, or validity of any particular claim against the Debtors; (b) a waiver of the
Debtors’ rights to dispute any particular claim on any grounds; (c) a promise or requirement to pay
any particular claim; (d) an implication or admission that any particular claim is of a type specified
or defined in this Interim Order or the Motion; (e) a request or authorization to assume any
agreement, contract, or lease pursuant to section 365 of the Bankruptcy Code; (f) a waiver or
limitation of the Debtors’ rights under the Bankruptcy Code or any other applicable law; or (g) a
concession by the Debtors that any liens (contractual, common law, statutory, or otherwise)
satisfied pursuant to the Motion are valid, and the Debtors expressly reserve their rights to contest
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4
the extent, validity, or perfection or seek avoidance of all such liens. Any payment made pursuant
to this Interim Order is not intended and should not be construed as an admission as to the validity
of any particular claim or a waiver of the Debtors’ rights to subsequently dispute such claim.
8. The banks and financial institutions on which checks were drawn or electronic
payment requests made in payment of the prepetition obligations approved herein are authorized
to receive, process, honor, and pay all such checks and electronic payment requests when presented
for payment, and all such banks and financial institutions are authorized to rely on the Debtors’
designation of any particular check or electronic payment request as approved by this Interim
Order without any duty of further inquiry and without liability for following the Debtors’
instructions.
9. The Debtors are authorized to issue postpetition checks, or to effect postpetition
fund transfer requests, in replacement of any checks or fund transfer requests that are dishonored
as a consequence of these chapter 11 cases with respect to prepetition amounts owed in connection
with any Taxes and Fees.
10. The contents of the Motion satisfy the requirements of Bankruptcy Rule 6003(b).
11. Notice of the Motion as provided therein shall be deemed good and sufficient notice
of such Motion and the requirements of Bankruptcy Rule 6004(a) and the Local Rules are satisfied
by such notice.
12. Notwithstanding anything to the contrary, the terms and conditions of this Interim
Order are immediately effective and enforceable upon its entry.
13. The Debtors are authorized to take all actions necessary to effectuate the relief
granted in this Interim Order in accordance with the Motion.
14. This Bankruptcy Court retains exclusive jurisdiction with respect to all matters
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5
arising from or related to the implementation, interpretation, and enforcement of this Interim
Order.
15. Notwithstanding anything contained in the Motion or this Interim Order, any
payment made, and any authorization of the Debtors contained herein shall be subject to the terms
and conditions contained in any interim or final orders entered by this Bankruptcy Court
authorizing the Debtors to obtain debtor-in-possession financing and/or authorizing the use of cash
collateral (each such order, a “DIP Order”). To the extent there is any inconsistency between the
terms of the DIP Order and any action taken or proposed to be taken hereunder, the terms of the
DIP Order shall control.
New York, New YorkDated: ____________, 2020
THE HONORABLE JUDGE [●]UNITED STATES BANKRUPTCY JUDGE
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EXHIBIT B
Proposed Final Order
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UNITED STATES BANKRUPTCY COURTSOUTHERN DISTRICT OF NEW YORK
)In re: ) Chapter 11
)LAKELAND TOURS, LLC, et al.,1 ) Case No. 20-11647 (___)
)Debtors. ) (Joint Administration Requested)
)
FINAL ORDER (I) AUTHORIZING THE PAYMENT OF CERTAIN PREPETITION TAXES AND FEES AND (II) GRANTING RELATED RELIEF
Upon the motion (the “Motion”)2 of the above-captioned debtors and debtors in possession
(collectively, the “Debtors”) for entry of a final order (this “Final Order”), (a) authorizing the
Debtors to negotiate, remit, and pay certain accrued and outstanding prepetition obligations
accrued in the ordinary course of business on account of the Taxes and Fees; and (b) granting
related relief, all as more fully set forth in the Motion; and upon the First Day Declaration; and
this Bankruptcy Court having jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334
and the Amended Standing Order of Reference from the United States District Court for the
Southern District of New York, dated January 31, 2012; and this Bankruptcy Court having found
that venue of this proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408
and 1409; and this Bankruptcy Court having found that the Debtors’ notice of the Motion and
opportunity for a hearing on the Motion were appropriate under the circumstances and no other
notice need be provided; and this Bankruptcy Court having reviewed the Motion and having heard
the statements in support of the relief requested therein at a hearing before this Bankruptcy Court
1 A complete list of each of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’ proposed claims and noticing agent at https://cases.stretto.com/WorldStrides. The location of the Debtors’ service address in these chapter 11 cases is: 49 West 45th Street, New York, NY 10036.
2 Capitalized terms used but not defined herein have the meanings given to such terms in the Motion.
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2
(the “Hearing”); and this Court having determined that the legal and factual bases set forth in the
Motion and at the Hearing establish just cause for the relief granted herein; and upon all of the
proceedings had before this Bankruptcy Court; and after due deliberation and sufficient cause
appearing therefor, it is HEREBY ORDERED THAT:
1. The Motion is granted on a final basis as set forth herein.
2. The Debtors are authorized in their sole discretion to: (a) negotiate, pay or remit
(or use applicable credits or overpayments to offset) the obligations that arose or accrued in the
ordinary course of business on account of the Taxes and Fees prior to the Petition Date and that
will become due and owing in the ordinary course of business during the pendency of these chapter
11 cases at such time when the Taxes and Fees are payable (including, for the avoidance of doubt,
as a result of the resolution of any Audit) and (b) negotiate, pay or remit Taxes and Fees that arise
or accrue in the ordinary course of business on a postpetition basis (including, for the avoidance
of doubt, as a result of the resolution of any Audit); provided, that in the event the Debtors make
a payment with respect to any Taxes and Fees for the prepetition portion of any “straddle” amount
and this Bankruptcy Court subsequently determines such amount was not entitled to priority or
administrative treatment under section 507(a)(8) or 503(b)(1)(B) of the Bankruptcy Code, the
Debtors may (but shall not be required to) seek an order from the Bankruptcy Court requiring a
return of such amounts and the payment of such amount shall, upon order of the Bankruptcy Court,
be refunded to the Debtors. Notwithstanding the relief granted herein or any actions taken
hereunder, nothing contained in this Final Order shall create any rights in favor of, or enhance the
status of any claim held by, any of the Authorities.
3. To the extent that the Debtors have overpaid any Tax or Fee, the Debtors are
authorized to seek a refund or credit.
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3
4. The Debtors are authorized to pay any amounts that later come due as the result (or
conclusion) of any pending or future audits in connection with their Taxes and Fees in the ordinary
course of business.
5. Notwithstanding the relief granted in this Final Order and any actions taken
pursuant to such relief, nothing in this Final Order shall be deemed: (a) an admission as to
the validity, priority, or amount of, or the basis for any particular claim against a Debtor entity;
(b) a waiver of the Debtors’ or any other party in interest’s right to dispute any particular claim on
any grounds; (c) a promise or requirement to pay any particular claim; (d) an implication or
admission that any particular claim is of a type specified or defined in this Final Order or the
Motion; (e) a request or authorization to assume any agreement, contract, or lease pursuant to
section 365 of the Bankruptcy Code; (f) a waiver or limitation of the Debtors’ or any other party
in interest’s rights under the Bankruptcy Code or any other applicable law; or (g) a concession by
the Debtors or any other party in interest that any liens (contractual, common law, statutory, or
otherwise) satisfied pursuant to this Final Order are valid and the Debtors and all other parties in
interest expressly reserve their rights to contest the extent, validity, or perfection or to seek
avoidance of all such liens. Any payment made pursuant to this Final Order should not be
construed as an admission as to the validity, priority, or amount of any particular claim or a waiver
of the Debtors’ or any other party in interest’s rights to subsequently dispute such claim.
6. The banks and financial institutions on which checks were drawn or
electronic payment requests made in payment of the prepetition obligations approved herein
are authorized to receive, process, honor, and pay all such checks and electronic payment requests
when presented for payment, and all such banks and financial institutions are authorized to rely on
the Debtors’ designation of any particular check or electronic payment request as approved by this
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4
Final Order without any duty of further inquiry and without liability for following the Debtors’
instructions.
7. The Debtors are authorized to issue postpetition checks, or to effect postpetition
fund transfer requests, in replacement of any checks or fund transfer requests that are dishonored
as a consequence of these chapter 11 cases with respect to prepetition amounts owed in connection
with any Taxes and Fees.
8. Notice of the Motion as provided therein shall be deemed good and sufficient notice
of such Motion and the requirements of Bankruptcy Rule 6004(a) and the Local Rules are satisfied
by such notice.
9. Notwithstanding anything to the contrary, the terms and conditions of
this Final Order are immediately effective and enforceable upon its entry.
10. The Debtors are authorized to take all actions necessary to effectuate the relief
granted in this Final Order in accordance with the Motion.
11. This Bankruptcy Court retains exclusive jurisdiction with respect to all matters
arising from or related to the implementation, interpretation, and enforcement of this Final Order.
12. Notwithstanding anything contained in the Motion or this Final Order, any payment
made, and any authorization of the Debtors contained herein shall be subject to the terms and
conditions contained in any interim or final orders entered by this Bankruptcy Court authorizing
the Debtors to obtain debtor-in-possession financing and/or authorizing the use of cash collateral
(each such order, a “DIP Order”), the documentation in respect of any such debtor-in-possession
financing or use of cash collateral, and any budget in connection with any such debtor-in-
possession financing and/or use of cash collateral. To the extent there is any inconsistency
between the terms of the DIP Order and any action taken or proposed to be taken hereunder, the
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5
terms of the DIP Order shall control. For the avoidance of doubt, the Debtors are not authorized to
make any payments pursuant to this Final Order to, or on behalf of, a non-debtor affiliate except
as permitted by the Budget (as defined in the DIP Order).
New York, New YorkDated: ____________, 2020
THE HONORABLE JUDGE [●]UNITED STATES BANKRUPTCY JUDGE
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EXHIBIT C
List of Authorities
20-11647 Doc 12 Filed 07/21/20 Entered 07/21/20 04:52:05 Main Document Pg 28 of 32
List of Authorities
Authority Address Type
Adams County, Colorado 4430 S. Adams County Parkway, 2nd Floor, Ste. C2100 Brighton, CO 80601
Property Taxes
AFIP Hipólito Yrigoyen 2251Buenos Aires
Income Taxes & Sales and Use Taxes
Agencia Estatal de Administración Tributaria Calle Alcalá 9Madrid, Spain
Income Taxes & Sales and Use Taxes
Alabama Alabama Department of Revenue, Business Privilege Tax Section, P.O. Box 327320Montgomery, AL 36132-7320
Income Taxes
Arizona Arizona Department of Revenue, P.O. Box 29085Phoenix, AZ 85038-9085
Income Taxes
Arlington County 2100 Clarendon Boulevard, Suite 200Arlington, VA 22201
Property Taxes & Regulatory and Other Taxes
Australian Tax Office (ATO) G.P.O. Box 9990Sydney NEW 2001
Income Taxes & Sales and Use Taxes
California Franchise Tax Board, P.O. Box 942857 Sacramento, CA 94257
Income Taxes
Canada Revenue Agency 55 Bay St NHamilton, ON L8R 3L4, Canada
Income Taxes & Sales and Use Taxes
Chilean Revenue Department Melgarejo 667, Valparaíso Income Taxes & Sales and Use Taxes
City of Alexandria Virginia City of Alexandria Business License, P.O. Box 34850Alexandria, VA 22334
Property Taxes & Regulatory and Other Taxes
City of Boston DOR, P.O. Box 7000 Boston, MA 02204
Property Taxes & Regulatory and Other Taxes
City of Charlottesville City of Charlottesville, P.O. Box 2854 Charlottesville, VA 22902
Property Taxes & Regulatory and Other Taxes
Colorado Colorado Department of Revenue Denver, CO 80261-0008
Income Taxes
Connecticut Department of Revenue Services State of Connecticut, P.O. Box 2976 Hartford, CT 06104-2976
Income Taxes
County of El Dorado 360 Fair LanePlacerville, CA 95667
Property Taxes & Regulatory and Other Taxes
County of Fairfax Department of Tax Administration, P.O. Box 10201Fairfax, VA 22035
Property Taxes & Regulatory and Other Taxes
County of Henrico Department of Finance, P.O. Box 90775 Henrico, VA 23273
Property Taxes & Regulatory and Other Taxes
Delaware P.O. Box 830Wilmington, DE 19899
Income Taxes
Direccion General de Impuestos Internos (DGII) Av México #48Santo Domingo 10204, Dominican Republic
Income Taxes & Sales and Use Taxes
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2
Authority Address Type
Directión de Impuestos y Aduanas Nacionales (DIAN)
Cra. 5Bogotá, Colombia
Income Taxes & Sales and Use Taxes
Directorate General of Public Finance 139 Rue de Bercy, 75574Paris, France
Income Taxes & Sales and Use Taxes
District of Columbia Office of Tax and Revenue, P.O. Box 96166 Washington, DC 20090-6166
Income Taxes
Douglas County Douglas County Government, 100 Third StreetCastle Rock, Colorado 80104
Property Taxes
Florida 2450 Shumard Oak Blvd.Tallahassee, FL 32311
Income Taxes
General Tax Directorate Bd Idriss II, BP, 3-42 Meknes Income Taxes & Sales and Use Taxes
Georgia Georgia Department of Revenue, P.O. Box 740239Atlanta, GA 30374-0239
Income Taxes
Harris County P.O. Box 922007Houston, TX 77292
Property Taxes
HM Revenue & Customs 73 Yorkshire St, Salford M3 5EG, United Kingdom
Income Taxes & Sales and Use Taxes
Idaho Idaho State Tax Commission, P.O. Box 83784Boise, ID 83707-3784
Income Taxes
Illinois 101 W Jefferson St.Springfield, IL 62702
Income Taxes
Indiana Indiana Department of Revenue, 100 N Senate Ave.Indianapolis, IN 46204
Income Taxes
Inland Revenue Department 12-22 Hawkestone St.Thorndon Wellington 6140, New Zealand
Income Taxes & Sales and Use Taxes
Italian Agency of Revenue via Giorgione n. 10600147 Roma
Income Taxes & Sales and Use Taxes
James City VA Government Center, 101 B Mounts Bay Road, Building BWilliamsburg, VA 23185
Property Taxes & Regulatory and Other Taxes
Kansas Kansas DOR 1883 W 21st St.Wichita, KS 67203
Income Taxes
Louisiana DOR 617 N 3rd St.Baton Rouge, LA 70802
Income Taxes
Maryland Maryland State Department of Assessments, P.O. Box 17052Baltimore, MD 21297
Property Taxes & Regulatory and Other Taxes
Maryland Comptroller of Maryland, Revenue Administration Division, 110 Carroll StreetAnnapolis, MD 21411-0001
Income Taxes
Massachusetts 436 Dwight St. #401Springfield, MA 01103
Income Taxes
Mexico Revenue 2540 El Paseo Rd. #2Las Cruces, NM 88001
Income Taxes & Sales and Use Taxes
Michigan Michigan Department of Treasury, P.O. Box 30774Lansing, MI 48909
Income Taxes
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3
Authority Address Type
Minister of Finance Nikis 5-7, 105 63Athens, Greece
Income Taxes & Sales and Use Taxes
Ministerio de Hacienda Av. 2, CatedralSan José, Costa Rica
Income Taxes & Sales and Use Taxes
Ministry of Finance Letenská 525/15, 118 10 Praha 1 - Malá Strana
Income Taxes & Sales and Use Taxes
Minnesota DOR 600 Robert St. N.St Paul, MN 55101
Income Taxes
Missouri DOR 301 W High St.Jefferson City, MO 65101
Income Taxes
Montana Montana Department of Revenue, P.O. Box 8021Helena, MT 59604-8021
Income Taxes
National Tax Agency 3-1-1 Kasumigaseki, Chiyoda-kuTokyo 100-8978, Japan
Income Taxes & Sales and Use Taxes
National Tax Service 58-8 Nakwon-dong, Jongno-guSeoul, South Korea
Income Taxes & Sales and Use Taxes
New Hampshire DOR 109 Pleasant St.Concord, NH 03301
Income Taxes
New Jersey 50 Barrack St.Trenton, NJ 08608
Income Taxes
New Mexico New Mexico Taxation & Revenue Dept., P.O. Box 25127Santa Fe, NM 87504-5127
Income Taxes
New York 66 John St., 2nd floorNew York, NY 10038
Income Taxes
North Carolina NC Department of Revenue, P.O. Box 25000Raleigh, NC 27640-0520
Income Taxes
NYC Department of Finance 59 Maiden Lane, 19th FloorNew York, NY 10038
Property Taxes
Oklahoma Oklahoma Tax Commission Income Tax, P.O. Box 26890Oklahoma City, OK 73126-0890
Income Taxes
Oregon Oregon Department of Revenue, P.O. Box 14780Salem, OR 97309-0469
Income Taxes
Pennsylvania Walnut St.Harrisburg, PA 17128
Income Taxes
Quincy Massachusetts City Hall, 1305 Hancock Street Quincy, MA 02169
Property Tax
Receita Federal do Brazil (RFB) Brasília, Distrito FederalBrazil
Income Taxes & Sales and Use Taxes
Rhode Island State of Rhode Island, Division of Taxation - Dept. #88, P.O. Box 9702Providence, RI 02940-9702
Income Taxes
Salt Lake City Assessor 2001 S State Street N2-600, P.O. Box 147421Salt Lake City, UT 84114
Property Taxes
San Diego San Diego County Assessor, 9225 Clairemont Mesa Blvd.San Diego, CA 92123
Property Taxes
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4
Authority Address Type
South African Reserve Revenue (SARS) Private Bag X923, PRETORIA, 0001 Income Taxes & Sales and Use Taxes
South Carolina SC Department of Revenue, P.O. Box 100153Columbia, SC 29202
Income Taxes
State Administration of Taxation 72 China National Highway 104, Lingcheng District, Dezhou, Shandong, China
Income Taxes & Sales and Use Taxes
Staunton Virginia Commissioner of Revenue, P.O. Box 4 Staunton, VA 24402
Property Taxes & Regulatory and Other Taxes
SUNAT (Superintendencia Nacional de Aduanas y de Administración Tributaria)
Jr. Junín N° 319 Centro de Lima, -01 Perú Income Taxes & Sales and Use Taxes
Tennessee 7175 Strawberry Plains Pike #300, Knoxville, TN 37914
Income Taxes
Thailand Revenue Department 90 Phahon Yothin 7 Alley, แขวง พญาไท Phaya Thai, Bangkok 10400, Thailand
Income Taxes & Sales and Use Taxes
Travis County Travis Central Appraisal District, P.O. Box 141864Austin, TX 78714
Property Taxes
Utah Utah State Tax Commission, 210 North 1950 WestSalt Lake City, UT, 84134-0180
Income Taxes
Vermont 133 State St.Montpelier, VT 05602
Income Taxes
Virginia 1957 Westmoreland St.Richmond, VA 23230
Income Taxes
Washington State Washington State Department of Revenue, P.O. Box 47471Olympia, WA 98504
Sales and Use Taxes & Regulatory and Other Taxes
Wisconsin 2135 Rimrock Rd.Madison, WI 53708
Income Taxes
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