Porter Hedges hires Tax Partner Jim Reardon from Bracewell & Giuliani

 In bracewell giuliani, Porter Hedges

James (Jim) D. Reardon has joined Porter Hedges as a partner in the tax section of the corporate practice group. He has a diverse practice, advising both public and private companies on minimizing tax liabilities to achieve specific operational and transactional objectives. He also provides a full range of services to individual and corporate taxpayers who are undergoing audits or challenging assessments on appeal with the Internal Revenue Service and state tax authorities.

As a counselor to closely-held partnerships, limited liability companies, S corporations, and their owners, he assists businesses reduce or eliminate federal corporate income taxation and achieve specific business goals. As a counselor to publicly-traded corporations, he advises with respect to the consolidated return rules, tax-free reorganizations, recapitalizations, and withholding tax issues.

Mr. Reardon advises foreign corporations making investments or conducting business in the United States with respect to U.S. tax issues such as the Foreign Investment in Real Property Tax Act, effectively connected income subject to U.S. income taxation, the branch profits tax, and dividend withholding tax. He advises foreign lenders with respect to the portfolio interest exemption and Foreign Account Tax Compliance Act. He also counsels U.S. corporations and their executives doing business or setting up legal entities overseas.

In the energy industry, Mr. Reardon represents oil and gas companies and other investors making strategic acquisitions or divestitures. He provides personal and corporate income tax advice with respect to the extraction, transportation and processing of natural resources in the upstream, midstream and downstream sectors. He also advises on financial products, physical commodities and cross-border withholding tax and transfer pricing issues where national tax authorities have focused on global trading and hedging operations in the energy industry.

Outside of the energy industry, Mr. Reardon has structured partnership profit interests, non-qualified deferred compensation plans, and other executive compensation arrangements. He has also helped tax-exempt organizations form joint ventures with private companies, advised technology companies raising seed capital, and structured international licensing and distribution arrangements.

With the Internal Revenue Service and state tax authorities focused on raising revenue, Mr. Reardon provides a full range of services to individual and corporate taxpayers who are undergoing audits or challenging assessments on appeal. His work includes eliminating interest and penalties and filing refund claims. He counsels companies on how to implement legislative, regulatory and accounting changes that affect their businesses.

Representative Matters

  • Represented Swiss Fund in disposition of $500 million Bakken Shale oil and gas assets.
  • Represented Swiss Fund in disposition of California San Joaquin Valley oil and gas company.
  • Represented Swiss Fund in acquisition of $40 million of oil and gas assets in Argentina.
  • Represented Oman Oil Company in structuring disposition of $700 million of Kazakhstan oil and gas assets held in offshore entities.
  • 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.

He received his J.D. from Boston College School of Law, LL.M. in Taxation from New York University School of Law, LL.M. in Corporate Law and Taxation from Universidad Pompeu Fabra (Spain), and an A.B. from Georgetown University.

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