Jon has extensive experience in advising on tax issues in the financial services industry. Jon’s clients have ranged from small cryptocurrency investment funds to global banks. The tax-efficient structuring of asset managers is a particular focus for Jon, including managers of cryptocurrency investment funds. He also has experience in advising on private equity M&A.
Jon’s financial services background includes advising:
- Private equity funds on the tax aspects of sales and acquisitions of middle market companies in industries ranging from software to seafood;
- Asset managers and hedge fund managers on tax-efficient structures both for their U.S. operations and non-U.S. operations;
- Underwriters and issuers on the tax aspects of cross-border IPOs and equity and debt offerings; and
- Tax treatment of novel financial products and instruments including cryptocurrency and litigation finance.
Specialized Financial Products: Cryptocurrency and Litigation Finance
One of Jon’s specialties is advising on the tax aspects of complex and novel financial products, including Cryptocurrency and litigation finance. During his time working in London, he was also part of the team advising on the U.S. tax treatment of “contingent convertible” bonds, better known as CoCos. He is the co-author of the first series of articles in Tax Notes on the taxation of litigation finance arrangements. His experience including advising on both the domestic and international US tax aspects of:
- Cryptocurrency and cryptocurrency option transactions;
- Litigation finance arrangements for both buyers and sellers; and
- Investments in U.S. loan origination by European institutional investors seeking to avoid U.S. federal income taxation on “effectively connected income” (ECI).
Token Offerings and ICOs
Jon has experience advising on the domestic and international tax consequences of initial coin offerings and token sales. Many tax questions come up in the context of ICOs, including the taxation of shareholders, the taxation of domestic and foreign entities engaged in token sales, the tax treatment of tokens issued as compensation, the use of foreign foundations, structuring ICOs, and which jurisdictions are preferable for an ICO from a tax perspective.