John D. Hollinrake, Jr.

John D. Hollinrake, Jr.

Of Counsel


John has over twenty-five years of experience advising clients on the federal income tax aspects of international and domestic mergers and acquisitions, reorganizations and restructuring, corporate distributions and other transactions with shareholders, debt and equity financings, entity formation, securitizations and structured finance.His practice focuses on business formations, joint ventures, acquisitions, combinations, sales, and tax planning. He has assisted clients with incorporations, tax-free corporate mergers, asset purchases and sales, cross-border transactions, strategic alliances, and joint ventures as well as general and limited partnerships and limited liability companies.

Education & Admissions

University of Houston Law Center (J.D., 1987), magna cum laude, Order of the Coif, Order of the Barons

University of Arizona (B.S. with High Distinction, Business, Administration-Accounting and Finance, 1980), Beta Gamma Sigma
Beta Alpha Psi
Phi Kappa Phi


  • Washington

News & Resources


Initial Guidance for New U.S. Excise Tax on Stock Repurchase Transactions: IRS Substantially Expands Scope of Applicable Canadian Companies
Inflation Reduction Act: New U.S. Excise Tax on Stock Repurchase Transactions Applicable to Certain Canadian Companies
Inflation Reduction Act: New Excise Tax Discourages Stock Repurchase Transactions
Cross-Border de-SPAC Structures
Plan Ahead to Reduce (or Eliminate) U.S. Withholding Tax when Selling or Transferring U.S. Subsidiaries holding U.S. Real Property
Canadian Corporations Acquiring U.S. Target Companies in Tax-Deferred Transactions: When Business Activities Outside the U.S. Matter
President Biden’s Made in America Tax Plan Would Treat More Cross-border Transactions as Inversion Transactions
Critical Reporting Obligation: Canadian-Owned U.S. Corporations and Disregarded Entities
Often Overlooked Exception to Withholding and Reporting Requirements under FATCA
“ECI” and its Trap for Unwary Canadian Investors in Partnerships and LLCs
The “Pot” Thickens – IRS Releases Marijuana Industry Resources
Covid-19 Tax Relief Makes Winners out of Losses (for some)
COVID-19 Delays EIN Process for Canadian Applicants
Stranded Canadians Taxed in the Time of Covid-19
Guide to Listing on the Canadian Securities Exchange
Loans to U.S. Subsidiaries Should Be Carefully Structured and Documented to Obtain U.S. Tax Benefits
Tax Consequences to U.S. Shareholders of Holding Shares in a Passive Foreign Investment Company or PFIC
When Will a Canadian Corporation be Treated as a Passive Foreign Investment Company?
Reminder of Required IRS Cost Basis Reporting for Canadian Companies
New U.S. Reporting Requirements for Issuers of Securities

News & Press Mentions

Chambers USA 2024 Recognizes Dorsey Lawyers and Practices
200 Dorsey Lawyers Selected for Inclusion in 2024 Best Lawyers in America, Lawyers of the Year, and Ones to Watch
Chambers USA 2023 Recognizes 12 Dorsey Lawyers and Four Practices in Seattle
Chambers USA 2023 Recognizes Dorsey Lawyers and Practices
Chambers USA 2022 Recognizes Dorsey Lawyers and Practices
Chambers USA 2019 Recognizes Dorsey Lawyers and Practices
12 Dorsey Lawyers in Seattle Selected for Inclusion in The Best Lawyers in America 2019
Chambers USA 2018 Recognizes Dorsey Lawyers and Practices in Seattle
13 Dorsey Lawyers in Seattle Selected for Inclusion in The Best Lawyers in America 2018
Chambers USA 2017 Recognizes Dorsey Lawyers and Practice Groups in Seattle
Chambers USA 2017 Recognizes Dorsey Lawyers and Practices
11 Dorsey Lawyers in Seattle Selected for Inclusion in The Best Lawyers in America 2017
Dorsey Wins 2016 Turnaround Atlas Award for Judicial Restructuring of the Year
Dorsey Wins 8th Annual International M&A Award
Dorsey Wins 10th Annual M&A Advisor Turnaround Awards
Dorsey Wins 14th Annual M&A Advisor Award for Real Estate Deal of the Year
9 Dorsey Lawyers in Seattle Selected for Inclusion in The Best Lawyers in America® 2016
Dorsey & Whitney Represents, Inc. in Preferred Stock Offering
Dorsey Represents Tekmira Pharmaceuticals on OnCore Biopharma Merger Agreement
11 Dorsey Seattle Lawyers Selected for The Best Lawyers in America® 2015 and Best Lawyers of the Year
Dorsey Advises Kodiak in Whiting Oil & Gas Deal

Select Presentations

  • Accidental Inversions
  • Tax Traps Presented by LLCs in U.S.-Canada Transactions
  • Online Tax Issues
  • U.S. Tax Consequences Regarding Canadian-U.S. Cross-Border Acquisitions
  • International Taxation of Electronic Commerce
  • International Joint Ventures and Strategic Alliances
  • Structuring Investment in Canada by U.S. Taxpayers
  • Structuring U.S. Investment by Foreign Taxpayers
  • Sale of Partnership Interests by Foreign Partners
  • Use of Netherlands Tax Treaty to Structure U.S. Investment
  • Tax Issues Regarding Joint Ventures and Strategic Alliances
  • Washington Limited Liability Companies: A Canadian - U.S. Perspective
  • Interpreting International Tax Treaties: A U.S. Perspective
  • Identifying and Addressing Tax Issues in Cross-Border Business and Investment Transactions

Industries & Practices

  • Banking & Financial Institutions
  • Canada Cross-Border Transactions
  • Emerging Companies
  • Energy & Natural Resources
  • Healthcare & Life Sciences
  • Mergers & Acquisitions
  • Mining
  • Oil & Gas
  • Tax

Professional & Civic

Professional Achievements

  • Washington State Bar Association
  • Certified Public Accountant, 1982-1991
  • American Bar Association, Section of Taxation 
  • Seattle Tax Group, Chair 2015, Member, 1999-Present


Chambers USA 2023Chambers 2022Chambers USA 2021  Ranked in Chambers USA 2020  Ranked in Chambers USA 2019 Leading Individual  Chambers USA 2018 Leading Individual  Ranked in USA Chambers 2017 Leading Individual

  • Listed in Best Lawyers in America©, 2012-2024
  • Named one of “America’s Leading Business Lawyers” by Chambers USA (Corporate/Commercial: Tax), 2017-2023
  • Impact Deal Award, International Tax Review, 2019
  • Rated AV Preeminent® by Martindale-Hubbell®
  • Named to Leading US West Coast Lawyers by Euromoney Legal Group 
  • Listed as a Washington Super Lawyer, 2003-2010
  • Listed in Best Puget Sound Lawyers by Seattle Business Magazine 
  • Listed in Top Lawyers by Seattle Met Magazine
John D. Hollinrake, Jr.