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    Global Problem Solving from Covington: Deal with Complex Problems Anywhere in the World

    • Apr 08, 2021

Jamin Koo

Associate

Washington +1 202 662 5772

  • About
  • Representative Matters
  • Credentials
  • About

    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.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters
    • 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.

    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
    • District of Columbia
    • New York
    • 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 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)

    Areas of Expertise

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