John is a Partner in Dorsey & Whitney's Tax practice, Head of the Palo Alto office and a member of the firm's Policy Committee. John has extensive experience in the following areas:
- Resolving U.S. tax issues related to cross-border mergers, acquisitions and investments.
- Providing inbound and outbound tax planning and advice related to multinational structures, worldwide tax reduction strategies, inversion transactions, transfers of intangibles, cost-sharing arrangements, controlled foreign corporation and passive foreign investment company issues, tax treaty eligibility, cross-border licensing, intercompany agreements, subsidiaries, branches and permanent establishments and the Foreign Account Tax Compliance Act (FATCA).
- Advising on cross-border transactions involving acquisitions and investments in Australia, Barbados, Brazil, British Virgin Islands, Canada, Cayman Islands, China, Hong Kong, India, Israel, Japan, Kazakhstan, Malaysia, Mauritius, Mexico, Russia, Sri Lanka, Switzerland, Taiwan and throughout the European Union.
- Advising on the formation of, and investments and dispositions by, private equity funds, including cross-border funds investing into India and China and funds investing into operating partnerships.
- Resolving issues related to multi-tier partnership structures as well as equity compensation of fund managers and service providers.
- Managing “unrelated business taxable income,” “effectively connected income” and non-U.S. tax consequences for fund investments.
Mergers & Acquisitions
- Tax planning and advice in connection with mergers, acquisitions, tax-free reorganizations, spin-offs, dispositions and financings for public and private companies.
- Developing, reviewing and negotiating deal structures, term sheets, transaction documents, escrow and earn-out arrangements, and post-acquisition restructurings.
- Identifying and resolving tax issues related to S corporations, LLCs and partnerships, including incentive compensation arrangements of partners and employees and multi-tier structures.