James D. Reardon

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

“Restructuring and M&A in the Energy Sector: Tools, Techniques, and Select Domestic and International Issues,” 11th Biennial Parker C. Field Oil and Gas Tax Conference, October 28, 2011.

Co-author, "Can a Cleverly Drafted Contract Save the Tax Day?" Tax Notes, January, 10, 2011.

"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).