Jon G. Neal

Partner

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Practices
Industries
Education
  • William & Mary Law School, JD, Member, William & Mary Law Review, 2004
  • University of Virginia, BA, 1997
Admissions
  • Virginia
  • New York
  • U.S. Tax Court
Affiliations

Member, Tax Section of American Bar Association

Member, Virginia State Bar Association

Member, New York State Bar Association

Jon represents and advises businesses and their owners on a broad range of corporate, partnership, and international tax planning, transactional and controversy matters, including cross-border mergers, joint-ventures, acquisitions, divestitures, restructurings, financings, repatriation strategies, tax credits and tax-treaty issues.

Having previously served as tax counsel for a Fortune 500 multinational corporation specializing in insurance, reinsurance and investment operations, Jon has substantial experience in insurance company taxation, tax-free restructurings and international transactions, including cross-border acquisitions and debt/equity financings.

Jon also regularly advises clients on structuring investments that produce federal and state tax benefits, with an emphasis on transactions involving New Markets Tax Credits, Energy Tax Credits, and Historic Tax Credits.

In the News

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T: +1 804 775 4722F: +1 804 698 2140Gateway Plaza
800 East Canal Street
Richmond, VA 23219-3916

Tax structuring for mergers and acquisitions across a range of industries, representing private equity funds as well as strategic buyers and sellers.

Structured, negotiated and documented a variety of joint ventures including ventures in real estate, energy, manufacturing and other industries.

Negotiated and documented the tax provisions of financing and credit agreements, primarily representing lenders and administrative agents.

Advised various clients in obtaining private letter rulings from the IRS on a variety of issues, including section 355 spin-offs, tax-free reorganizations and other matters.

Negotiated, prepared and closed real estate and tax credit transactions (including structuring partnership and investment documents for Historic, New-Markets and Low-Income Housing Tax Credit partnerships and transactions).

Represented numerous clients in transactions involving Section 45 tax credits for the production of electricity from renewable resources, including wind, biomass, and landfill gas facilities.

Represented numerous clients in transactions involving Section 48 tax credits for solar projects and combined heat and power projects.

Represented numerous clients in making submissions to the Offshore Voluntary Disclosure Initiative programs.

Co-author, Business and Tax Considerations in the Purchase and Sale of a Privately Held Business, Outline for University of Virginia 64th Annual Conference on Federal Taxation, June 7, 2012
Co-author, UK Remittance Basis Charge to Offset U.S. Income Tax, Practical International Tax Strategies, September 15, 2011
Co-author, Recent Legislative Developments in Renewable Energy Tax Incentives, Practical U.S./Domestic Tax Strategies, December 2009
Co-author, Stimulus Act Provides Extensive Tax Incentives for Renewable Energy, Practical U.S./Domestic Tax Strategies, February 2009
Presenter, "Tax Considerations in the Purchase and Sale of an Insurance Company," Federal Bar Association Insurance Tax Conference, Washington, D.C., June 3, 2016
Presenter, "What to Know Before You Go: Hot Topics in Insurance M&A," American Bar Association, Section of Taxation Meeting, Denver, Colorado, September 19, 2014
Presenter, "New Market Tax Credits – Structuring Considerations," Webinar CLE Program, American Bar Association, Real Estate Section, March 2013
Presenter, "New Markets Tax Credits - The Latest for Real Estate Lawyers," eCLE for American Bar Association, Real Property Section, September 12, 2012
Presenter, "Business and Tax Considerations in the Purchase and Sale of a Privately Held Business," University of Virginia 64th Annual Conference on Federal Taxation, June 7, 2012
Presenter, "Historic Tax Credits – Basics and Structuring Considerations," CDFE Intro Tax Credit Finance Course, August 11-12, 2011
Presenter, "Annual Update on Developments in Federal and State Tax Law," Virginia State Bar Annual Meeting, June 2011
Presenter, "New Markets Tax Credits: Basics and Identifying Opportunities," McGuireWoods Webinar, June 10, 2010
Presenter, "Bringing a Sustainable Credit to Market," Bond Buyer's Financing Sustainable Energy and Efficiency Conference, May 20, 2010