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Jamin Koo

Associate

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 from different industries on various issues involving tax credits and other tax provisions of the Chips & Science Act and the Inflation Reduction Act and drafting comments to the government.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters
    • Advise the formation, operation, and termination of joint ventures between corporations in the pharmaceutical and technology sectors.
    • 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.
    • 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 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 real estate investment trust on its REIT qualification, business restructuring, and restructuring of financing arrangements.
    • Advise families with restructuring family-owned businesses and gift and estate planning, involving valuation of businesses and real property.
    • 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.
    • 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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