Jennifer A. Ray is a counsel in the Tax Group in the firm's Washington D.C. office.
Jen advises clients, including public and private companies, investment funds, and tax-exempt entities, on tax aspects of corporate and partnership transactions, including mergers, acquisitions, joint ventures, and debt and equity financings. Her practice focuses on structuring related to pass-through entities such as partnerships, LLCs, and S corporations, and compensation-related issues arising in such transactions under Code sections 280G and 409A. Jen's experience includes representation of sponsors of investment funds, including fund structuring, operation, and investments.
Jen has also represented clients in tax controversies with the Internal Revenue Service Appeals Office and the U.S. Tax Court.
Publications
· "Navigating the Research Credit," Tax Notes (September 20, 2011). Authors: Alex E. Sadler and Jennifer A. Ray.
· "Tax Court Changes Course on Contingent Options," Journal of Taxation of Financial Products, Vol. 8, Issue 2 (2009). Author: Jennifer A. Ray.
· "New York Guts Commercial Aircraft Exemption from Sales and Use Tax for Transportation Services Provided to Affiliated Persons," National Business Aviation Association (May 2009). Author: Jennifer A. Ray.
· "American Recovery and Reinvestment Act of 2009," published by CCH (2009). Contributing Authors: Alex E. Sadler, Charles C. Hwang and Jennifer A. Ray.
· "Emergency Economic Stabilization Act of 2008: Law, Explanation and Analysis," published by CCH (2008). Contributing Authors: Alex E. Sadler, Charles C. Hwang and Jennifer A. Ray.
· "Electronic Tax Trials: Taking Advantage of the Tax Court's Electronic (North) Courtroom," Journal of Tax Practice & Procedure (August-September 2008). Co-Authors: Alex E. Sadler and Jennifer A. Ray.
Alerts & Newsletters
· "Proposed Legislation To Tax "Carried Interests" as Ordinary Income," Investment Funds Alert (September 28, 2011). Contacts: Jennifer A. Ray, Paul J. Pollock, Richard B. Holbrook Jr.