Jon’s business tax practice ranges from the tax aspects of complex cross-border transactions, to representing taxpayers defending against audits by the IRS and California Franchise Tax Board, to advising individuals disclosing foreign accounts and foreign assets as part of the IRS Offshore Voluntary Disclosure Program (OVDP) (in amounts ranging from the multi millions to much smaller amounts). Jon’s services include:
M&A and Entity Selection
- Entity Selection (both newly-formed companies as well as entities created to acquire established targets);
- Sales, acquisitions, and investments in private companies taxed as pass-throughs (partnerships, LLCs, S-Corporations);
- Equity Compensation;
- Joint Ventures;
- Earnouts and contingent payments; and
- Post-acquisition structuring.
Bankruptcy and Debt Workouts
- preserving tax attributes in debt workouts inside and outside of Chapter 11 bankruptcies and
- debt-for-equity swaps.
- investments by foreign investors into the U.S.; and
- outbound investments by U.S. taxpayers outside the U.S.
Investment losses, Business losses
- tax losses for bad business debts and theft losses; and
- tax losses for restitution payments and clawback of compensation.