Having started his career as a transactional tax lawyer based in London, Jon has over ten years of experience in international tax. Jon’s experience ranges from structuring international operations and payment flows to withholding tax. Jon’s background working on cross-border transactions makes him particularly efficient at dealing with international tax matters, both for individuals and businesses.
If you’re expanding your business internationally, engaging in a cross-border transaction, moving to the United States, investing in the United States, or confronting an international tax issue that is unfamiliar to you, you won’t find anyone else more determined and persistent to find a creative solution to your problem. If you’re facing a difficult compliance problem, Jon can help establish procedures to facilitate and simplify your compliance.
Here are some examples of Jon’s experience:
- Advised individual taxpayers on the tax treatment of their foreign investments.
- Created tax-efficient structures for foreign investors investing in the U.S. and U.S. investors investing in foreign assets.
- Structured complex partnership agreement to provide parity treatment for managers resident in the U.S. and India who received different forms of tax-advantaged equity awards (profits interests and options).
- Provided withholding tax compliance advice for foreign bank entering into custodian relationship with Interactive Brokers.
- Advised on tax aspects of complex multi-stage, multi-year debt workout, debt pushdown and corporate restructuring of a US-owned German auto parts manufacturer organized as a foreign operating partnership with foreign corporate subsidiaries.
- Advised buyer on tax aspects of deemed liquidation of U.S. subsidiary into Luxembourg parent corporation in preparation for the sale of the U.S. subsidiary.
For more information, see Inbound Investment for non-U.S. investors investing in the United States, Outbound for U.S. taxpayers investing abroad, Individuals if you are moving to or from the United States, and Compliance for questions related to tax compliance.