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Jamin Koo advises clients across a broad range of tax issues, including domestic and international tax planning, acquisition and financing transactions, and tax controversies. His expertise includes taxation of debt instruments, derivatives, and other financial instruments.
- Counsel issuers on the tax structuring of equity derivatives transactions to hedge convertible or exchangeable notes.
- Advise 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.
- Represent creditors and borrowers in financing transactions, including financing for professional sports club purchase and stadium construction.
- Represent issuers and underwriters in capital market transactions and buyers and sellers in M&A transactions, including a transaction involving an inversion analysis.
- Advise a client on the tax treatment of insurance and annuity contracts to facilitate foreign investment in domestic securities and real estate projects.
- Represent a client in a Congressional investigation in connection with its syndicated conservation easement transactions.
- Advised a real estate investment trust on its REIT qualification and its financing arrangements involving debt restructuring.
- Counseled companies on domestic and international restructuring of their businesses, including distressed businesses having cancellation of indebtedness issues.
- Advised clients on tax accounting of income and expenses, related to royalty payments, advance payments, and deposits.
- Conducted an internal investigation on behalf of the audit committee of a company regarding tax and accounting fraud allegations.
- Advised clients on the structuring of business activities and impact of the 2017 tax reform, including GILTI, repatriation tax, interest deduction limitations, and qualified business income deduction.
- Advised an estate on its estate tax return preparation, involving valuation of businesses and real property.
Pro Bono
- Represent an individual serving a life sentence in his federal habeas proceeding to vacate his convictions.
- Represent individual veterans and a veteran organization in seeking tax refunds pursuant to Combat-Injured Veterans Tax Fairness Act of 2016.
- Advised tax-exempt organizations on incorporation and financing.
- Advised clients on the tax structuring of settlement proceeds following wrongful conviction and personal injury claims.
- 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), Board Member
Previous Experience
- Technology Specialist (Patent Agent) (2012-2013)
- Laboratory for Aviation and the Environment, Research Specialist and Research Assistant (2009-2012)
Tax On-Demand Webinars
October 2020
Covington is pleased to offer this series of prerecorded webinars focused on recent tax developments. Registration is required for each seminar. We hope you will find the programs to be of value and encourage you to contact presenters with any questions you may have. CLE: Each program is an intermediate/advanced level program. Lawyers who have been admitted to ...
April 5, 2019
NEW YORK—Covington represented IFM Tre, Inc. in its sale to Novartis for a $310 million upfront cash payment and up to $1.265 billion in milestone payments (for a total of $1.575 billion). IFM Tre develops chemically distinct systemic, gut-directed, and CNS-penetrant drug candidates to address several indications triggered by NLRP3, including metabolic, ...
May 1, 2018
WASHINGTON—Covington advised Elbit Systems Ltd. in its $120 million acquisition of the assets and operations of the privately owned U.S. company, Universal Avionics Systems. Elbit Systems is an international high technology company engaged in a wide range of defense, homeland security, and commercial programs throughout the world. Universal Avionics is a ...
2013, Atmospheric Environment