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.
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William & Mary Law SchoolJD
Member, William & Mary Law Review
2004 - University of VirginiaBA1997
Member, Editorial Advisory Board, Tax Authority International Board, Law360, 2022
Member, Tax Section of American Bar Association
Member, Virginia State Bar Association
Member, New York State Bar Association
- Speaker, Renewable Energy Project Development on Federal Land, Strafford Publications, Inc., CLE Webinar, March 30, 2021
- Speaker, Optimizing Opportunity Zone Investments, Complimentary Webinar, October 30, 2019
- Speaker, "Taking Advantage of Opportunity Zones to Defer Recognition of Gains," New Developments in Wealth Planning, Richmond, VA, October 24, 2019
- Speaker, "Taking Advantage of Opportunity Zones to Defer Recognition of Gains," 14th Annual Fiduciary Advisory Services Seminar, Wednesday, October 2, 2019
- Speaker, New Developments in Wealth Planning Seminar, October 25, 2018
- Moderator, "Tax Reform and Its Potential Impact on Transactions," 2018 Independent Sponsor Conference, October 3, 2018
- 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
- New York
- Virginia
- U.S. Tax Court
Selected for inclusion in The Best Lawyers in America, Tax Law, Woodward/White, Inc., 2024, 2025
- Author, IRS Issues New Safe Harbor for 10% Domestic Content Bonus, McGuireWoods Legal Alert, May 24, 2024
- Author, Treasury and IRS Issue Guidance for Section 45X Advanced Manufacturing Production Credit, McGuireWoods Legal Alert, January 17, 2024
- Author, IRS Opens Portal to Register Credits for Direct Payments or Transfers, McGuireWoods Legal Alert, January 17, 2024
- Author, IRS and Treasury Seek Comments on Direct Pay and Domestic Content Overlap, McGuireWoods Legal Alert, January 17, 2024
- Author, Treasury and IRS Issue Guidance for Section 45V Hydrogen Production Tax Credit, McGuireWoods Legal Alert, January 17, 2024
- Author, IRS Refreshes and Codifies Energy Property Tax Credit Guidance in Proposed Section 48 Regulations, McGuireWoods Legal Alert, November 21, 2023
- Author, IRS Halts ERC Claims Processing Amid Surge of Questionable Submissions, McGuireWoods Legal Alert, September 19, 2023
- Author, IRS Proposes Prevailing Wage and Apprenticeship Regulations, McGuireWoods Legal Alert, August 30, 2023
- Author, IRS Issues Guidance for Direct Payments of Energy Tax Credits, McGuireWoods Legal Alert, June 20, 2023
- Author, IRS Issues Guidance for Transferability of Energy Tax Credits, McGuireWoods Legal Alert, June 16, 2023
- Author, IRS Issues More Guidance for Section 48C Advanced Energy Project Tax Credit Allocation Program, McGuireWoods Legal Alert, June 2, 2023
- Author, Domestic Content 10% Bonus Guidance Released (IRS Notice 2023-38), McGuireWoods Legal Alert, May 15, 2023
- Author, Opening Soon — Application for Section 48C Advanced Energy Project Investment Tax Credit, McGuireWoods Legal Alert, May 9, 2023
- Author, IRS Issues Guidance for Energy Community Bonus Tax Credits – Notice 2023-29, McGuireWoods Legal Alert, April 5, 2023
- Author, Energy Credits — Treasury, IRS Promise Direct Pay and Transferability Registry and Guidance, McGuireWoods Legal Alert, March 27, 2023
- Author, IRS Issues Guidance for Energy Tax Credits in Low-Income Communities – Notice 2023-17, McGuireWoods Legal Alert, February 16, 2023
- Author, Inflation Reduction Act Extends and Modifies Tax Credits for Solar Projects, McGuireWoods Legal Alert, February 6, 2023
- Author, IRS Issues Prevailing Wage and Apprenticeship Guidance — Starts 60-Day Clock, McGuireWoods Legal Alert, November 30, 2022
- Author, Inflation Reduction Act Extends and Modifies Tax Credits for Wind Projects, McGuireWoods Legal Alert, August 24, 2022
- Author, U.S. Senate Introduces the Inflation Reduction Act, McGuireWoods Legal Alert, August 2, 2022
- Author, Build Back Better Act, McGuireWoods Legal Alert, September 24, 2021
- Author, IRS Further Extends Continuity Safe Harbor for 2016 and Later Renewable Energy Projects, McGuireWoods Legal Alert, July 2, 2021
- Author, U.S. Senate Introduces the Clean Energy for America Act, McGuireWoods Legal Alert, April 29, 2021
- Author, Carbon Capture Tax Credits — IRS Issues Final Treasury Regulations, McGuireWoods Legal Alert, January 22, 2021
- Author, Continuity Safe Harbor Extended for Offshore Wind, Renewable Energy Projects on Federal Land, McGuireWoods Legal Alert, January 12, 2021
- Author, New Tax Extender Legislation Passed for Renewable Energy, Carbon Capture Projects, McGuireWoods Legal Alert, December 23, 2020
- Author, IRS Proposes Regulations for Carbon Capture Tax Credit, McGuireWoods Legal Alert, June 10, 2020
- Author, Wind PTC and Solar ITC Gain COVID-19 Construction Relief From IRS, McGuireWoods Legal Alert, May 29, 2020
- Author, Business Tax Relief in the CARES Act, McGuireWoods Legal Alert, March 27, 2020
- Author, IRS Provides Carbon Capture Tax Credit Guidance and Safe Harbor, McGuireWoods Legal Alert, February 24, 2020
- Author, Treasury Proposes Guidance to Minimize Tax Consequences of LIBOR Phase-Out, McGuireWoods Legal Alert, October 16, 2019
- Author, 2019 Tax Credit Inflation Adjustment Factor: 2.5 Cents per kWh for Wind Facilities, McGuireWoods Legal Alert, August 13, 2019
- Author, Beginning Construction Continuity Safe Harbor Extended for National Security Concerns, McGuireWoods Legal Alert, July 24, 2019
- Author, Opportunity Zone Fundraising and Public Comment Update for 2019, McGuireWoods Legal Alert, June 27, 2019
- Author, Carbon Sequestration Tax Credits – IRS Requests Comment on Section 45Q Regulations, McGuireWoods Legal Alert, May 8, 2019
- Author, Treasury Releases Second Round of Proposed Regulations to Encourage Investment in Opportunity Zones, McGuireWoods Legal Alert, April 29, 2019
- Author, Key Takeaways From the BEAT Proposed Regulations, McGuireWoods Legal Alert, January 3, 2019
- Author, Opportunity Zone Proposed Regulations Move Investors and Funds Forward, McGuireWoods Legal Alert, November 16, 2018
- Author, IRS and Treasury Issue Opportunity Zone Proposed Regulations and Guidance, McGuireWoods Legal Alert, October 19, 2018
- Author, New Opportunities Follow Expansion of Section 45Q Carbon Sequestration Credits, McGuireWoods Legal Alert, July 11, 2018
- Author, IRS Provides Solar ITC Guidance on the Begin-Construction Requirement, McGuireWoods Legal Alert, June 29, 2018
- 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