James D. Reardon
Partner
Lori David
713.223.2300 x2471
Jim Reardon's primary practice areas include private equity, mergers and acquisitions, partnership tax, financial products, and the taxation of cross-border transactions, including in-bound and out-bound investments. His clients include private equity funds investing in the energy sector, hedge funds, multinational public corporations, MLPs, financial institutions and private investors.
A significant part of Mr. Reardon's tax practice involves public utilities, oil and gas exploration and production companies, and investment partnerships. His experience adds value to cross-border holding company structures, joint ventures, acquisitions and dispositions of assets, and the repatriation of earnings in a tax-efficient manner.
Mr. Reardon focuses on representing offshore opportunity funds, hedge funds and private equity.
Representative Matters
Represented public utility company in disposition of nuclear power facilities and with respect to sale-leaseback transactions involving co-generation plants.
Structured sale of $1.6 billion pipeline partnership.
Obtained private letter ruling on tax-free spin-off of telecommunications company.
Structured sale of assets of $1.5 billion electronics distributor to Berkshire Hathaway.
Advised offshore funds with respect to investments in the US.
Advised US-based multinational companies on foreign holding company structures, including leverage, exit strategies and foreign tax credit management.
Publications and Speeches
"U.S. Taxation of Sovereign Wealth Funds," Tax Notes International, Aug. 11, 2008, p. 507.
"Hedge Funds, ECI and Economic Substance," Tax Notes, Feb. 19, 2007, p. 789.
"Marrita Murphy: The Flip Side of the Economic Substance Doctrine," Tax Notes, Sept. 25, 2006, p. 1167.
"The Enron Bankruptcy: What Went Wrong," 4 Derivatives & Financial Instruments 158 (2002).
"Offshore Hedge Funds – Doing Business in the United States," 15 Journal of Taxation of Financial Institutions 19 (2001).
"Casting Light on Investment Funds and Fiscal Secrecy," 3 Derivatives & Financial Instruments 199 (2001).
"When Is a Derivative Treated as Debt for US Federal Income Tax Purposes?," 3 Derivatives & Financial Instruments 62 (2001).
"Source Rules with respect to the Sale of a Partnership Interest," 2 Derivatives & Financial Instruments 289 (2000).
Bufete Cuatrecasas, Business Law Guide to Spain (Bronheim & Reardon trans., CCH EDITIONS, ed., 1994).
Angulo & Reardon, "The Apparent Political and Administrative Expediency Exception Established by the Supreme Court in United States v. Humberto Alvarez-Machain to the Rule of Law as Reflected by Recognized Principles of International Law," XIV B.C. Int’l & Comp. L. Rev. 245 (1993).
Education
LL.M., Taxation, New York University School of Law, 1996
LL.M., Corporate Law and Taxation, Universidad Pompeu Fabra, 1994
J.D., Boston College Law School, 1991
A.B., Georgetown University, 1987
Bar Admissions
Connecticut
District of Columbia
New York
Texas
Affiliations
New York Bar Association
Texas State Bar Association
The University Club of New York