Jon G. Neal Partner

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

Having previously served as tax counsel for a Fortune 500 multinational corporation specializing in insurance, reinsurance and investment operations, Jon has extensive experience advising on 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.

Experience

  • 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 joint 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 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 clients in transactions involving Section 45 tax credits for the production of electricity from renewable resources, including wind, biomass and landfill gas facilities.
  • Represented clients in transactions involving Section 48 tax credits for solar projects and combined heat and power projects.