Paul Jacokes, a member of Sutherland's Tax Practice Group, represents domestic and multi-national companies in federal income tax planning and controversy matters with a particular emphasis on financing transactions and complex financial instruments. He frequently advises clients on tax issues relating to the hedging of financial and other types of business risk using derivatives, in both a domestic and international context. Paul also has extensive experience with tax issues pertaining to securities and commodities dealers and traders, hedge funds, and insurance companies, and has recently advised on several innovative transactions involving securitization of insurance risks. Paul served as legislation counsel to the Congressional Joint Committee on Taxation and spent several years as in-house tax counsel advising the corporate finance department of a large financial institution. He has served on the adjunct faculty of Georgetown University Law School, teaching a graduate course on the taxation of corporate mergers and acquisitions. Representative Experience Paul's representative experience includes: · Providing advice to Great-West Lifeco and its U.S. affiliates on tax issues relating to the $3.9 billion acquisition of Putnam Investments. · Providing advice to Manulife Financial Corporation and its U.S. affiliates on tax issues relating to a 1.2 billion Canadian dollar cross-border financing transaction. · Providing tax advice to United States Oil Fund, an exchange-traded vehicle (ETV) that was the first exchange-traded partnership designed to track changes in crude oil prices. · Providing tax advice to a major multi-national insurance company on securitization transactions involving transfer of risks relating to guaranteed level premium insurance policies subject to NAIC Regulation XXX and AXXX to the capital markets. · Advising several major insurance companies on tax issues raised by innovative annuity products with a guaranteed minimum withdrawal benefit feature. · Negotiating favorable administrative settlements with the IRS for a domestic insurance company with respect to a tax-advantaged financial transaction, and for a U.S. subsidiary of a foreign corporation with respect to cross-border financing transactions involving hybrid instruments. · Assisting several Fortune 500 companies in negotiating tax provisions of Schedules to ISDA Master Agreement with dealer counterparties. Professional and Community Involvement · Member, Taxation and Financial Transactions Committee, Taxation Section, American Bar Association · Member, District of Columbia Bar Recent Speaking Engagements · Speaker, "Current Developments in Financial Products and Transactions," Tax Executives Institute (TEI), Houston, Texas (May 2007) Legal Alerts Legal Alert: Assignment of the Times: New Tax Rules Respond to Concerns Regarding Assignment of Derivative Contracts Required by Dodd-Frank
July 25, 2011 Legal Alert: IRS Issues Initial Rulings on "Contingent" Annuities
December 7, 2009 Legal Alert: Counterparty Rights in the Lehman Brothers Bankruptcy
October 10, 2008 Legal Alert: House Financial Services Subcommittee Approves the Insurance Information Act of 2008 to Create an Office of Insurance Information
October 10, 2008 Legal Alert: Moving Forward with the Bailout - The Emergency Economic Stabilization Act of 2008 Becomes Law
October 3, 2008 Legal Alert: Progress on the "Bailout" Proposal - The Senate Passes an Expanded Emergency Economic Stabilization Act of 2008
October 2, 2008 Legal Alert: The Evolving "Bailout" Proposal - Emergency Economic Stabilization Act of 2008
September 29, 2008 Legal Alert: Lehman Brothers Bankruptcy-ISDA Issues
September 15, 2008 Events Tax Executives Institute (TEI)
May 2007 |