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Jamin Koo

Special Counsel

New York +1 212 841 1290

  • About
  • Representative Matters
  • Credentials
  • About

    Jamin Koo advises clients across a broad range of tax issues, including international and domestic tax planning and acquisition and financing transactions. He works with numerous U.S. and non-U.S. clients (in particular, several Asia-based clients) on cross-border investments, joint ventures, and restructurings. His expertise includes taxation of debt instruments, derivatives, and other financial instruments, and he has been providing tax advice related to digital assets to a number of clients.

    Most recently, with his background in engineering and environmental science, Jamin has been advising clients in a number of industries on tax credit issues related to the Chips & Science Act and the Inflation Reduction Act to maximize credits and explore monetization methods. He has been drafting numerous comment letters to Treasury and the IRS.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters
    • Counsel domestic and international clients on the implementation of the CHIPS & Science Act and the Inflation Reduction Act to maximize tax credit benefits, including structuring of their qualifying investments and exploring credit monetization methods.
    • Assist preparing comment letters to the Treasury Department and IRS related to tax credits for clean electricity generation, carbon capture, EVs, and semiconductor manufacturing.
    • Advise the formation, operation, and termination of joint ventures between corporations in the energy, pharmaceutical, and technology sectors.
    • Advise clients on the structuring of business activities and impact of the 2017 tax reform, including GILTI, BEAT, repatriation tax, interest deduction limitations, and qualified business income deduction.
    • Counsel companies on domestic and international restructuring of their businesses, involving distressed businesses having cancellation of indebtedness consequences and intercompany financing structures.
    • Represent buyers and sellers in M&A transactions, including cross-border transactions involving an inversion analysis and issuers and underwriters in capital market transactions.
    • Advise a real estate investment trust on its REIT qualification, business restructuring, equity offering, and restructuring of financing arrangements.
    • Counsel issuers on the tax structuring of equity derivatives transactions to hedge convertible or exchangeable notes.
    • Represent creditors and borrowers in financing transactions, including financing for professional sports club purchase and stadium construction.

    • Advised clients on the tax treatment of installment sales of franchise rights, including the accrual of original issue discount on the installment obligations, modifications to the payment terms and purchase price, and interest on deferred tax liabilities.
    • Advised a client on the tax treatment of insurance and annuity contracts to facilitate foreign investment in domestic securities and real estate projects.
    • Advised clients on tax accounting of income and expenses, related to royalty payments, advance payments, and deposits.
    • Advised families with restructuring family-owned businesses and gift and estate planning, involving valuation of businesses and real property.
    • Represented a multinational corporation in a Congressional investigation on its tax planning.
    • Conducted an internal investigation on behalf of the audit committee of a company regarding tax and accounting fraud allegations.

    Areas of Expertise

  • Credentials
    Education
    • University of Pennsylvania Law School, J.D., 2016
        • Bernard A. Chertcoff Prize for Taxation
    • Massachusetts Institute of Technology, S.M., 2011
    • University of Illinois, B.S., 2009
    Bar Admissions
    • New York
    • District of Columbia
    • U.S. Patent and Trademark Office
    Languages
    • Korean
    Pro Bono
    • Represent an individual serving a life sentence in his federal habeas proceeding to vacate his wrongful convictions.
    • Advise clients on the tax structuring of settlement proceeds in connection with a wide range of claims, such as claims under the Federal Tort Claims Act, Section 1983 claims, Fair Housing Act discrimination claims, wrongful conviction claims, and other personal injury claims.
    • Represent individual veterans and a veteran organization in seeking tax refunds pursuant to the Combat-Injured Veterans Tax Fairness Act of 2016.
    • Advised tax-exempt organizations on incorporation and financing.
    • Represented a foreign national in obtaining the permanent residency status and permanent residents in applying for citizenship.
    Memberships and Affiliations
    • Asian Pacific American Bar Association Educational Fund (AEF), President and Board Member (2020–2022)
    Previous Experience
    • Technology Specialist (Patent Agent) (2012–2013)
    • MIT Laboratory for Aviation and the Environment, Research Specialist and Research Assistant (2009–2012)

    Areas of Expertise

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