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Home | BakerHostetler

Ronald Baumgarten Expects Upcoming Trade Policies to be Similar to Last Republican Administration

Patrick Campbell, Jonathan New Author Law360 Article on Whistleblower Programs

DOJ Antitrust Division Adds to Guidance on the Evaluation of Corporate Compliance Programs in Criminal Antitrust Investigations

BakerHostetler Alumni Newsletter – Fall 2024

<p>Jeff has a broad-based practice involving tax controversies, tax litigation and tax investigations – including tax promoter investigations; structuring corporate, partnership, REIT and venture capital transactions; restructuring global enterprises to help minimize worldwide effective tax rates; bankruptcy taxation; and domestic and cross-border tax planning. He also represents clients' immediate and longer-term interests before government enforcement officials, federal policymakers and on Capitol Hill, and has served as a tax authority to help parties resolve contractual tax indemnity matters and post-transaction tax disputes.</p>
<p>Jeff also serves as firmwide Chair of BakerHostetler’s Tax Group, which is among the largest law firm tax practices in the U.S., and as managing partner of the firm’s Washington, D.C., office. Before returning to the firm in 2003, Jeff served as Senior Advisor to the Assistant Secretary, Tax Policy, at the U.S. Department of the Treasury. While at the Treasury, Jeff was responsible for providing advice on a wide range of tax policy and technical issues, including tax legislation and corporate, partnership, REIT and financial sector tax guidance. He also was one of the primary authors of the final tax shelter regulations, is author of the Tax Management Portfolio,<em> Tax Shelters</em>, T.M. 798, and co-author of the Tax Management Portfolio, <em>Reportable Transactions</em>, T.M. 648-2nd.</p>
<p>Jeff has assumed numerous positions of service in academia and to the legal profession. He is a fellow of the American College of Tax Counsel and a member of the American Bar Association, Section of Taxation, where he has served in various capacities, including as chair of the Affiliated and Related Corporations Committee and chair of the Committee on Government Submissions. He has been an adjunct professor in the LL.M. tax programs at Georgetown University Law Center and Case Western Reserve University School of Law, and has served on the editorial advisory boards of various tax publications. Jeff has written and lectured extensively on tax topics and has chaired numerous tax programs, panels and task forces. He is routinely among those named in Chambers USA: America's Leading Lawyers for Business,&nbsp;The Legal 500 United States<em>, The</em>&nbsp;<em>Best Lawyers in America®</em>, Lexology Index (formerly Who's Who Legal) and Super Lawyers, and was a past president of the Tax Club and editor-in-chief of <em>The Tax Lawyer</em>.</p>

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Video: Jeff Paravano Highlights Our Tax Team

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LL.M., Georgetown University Law Center, 1993, 

J.D., Georgetown University Law Center, 1991, 

B.S.B.A., John Carroll University, 1988, 

<ul>
<li>Law360: Tax Authority Federal Editorial Advisory Board (2024)</li>
<li>ITR World Tax 2023: Notable Practitioner, District of Columbia</li>
<li>JD Supra Readers&#8217; Choice Award (2022)
<ul>
<li>Top Ten Author in Tax</li>
</ul>
</li>
<li>Chambers USA: Tax in the District of Columbia
<ul>
<li>Band 2 (2024), Band 3 (2012 to 2023), Band 4 (2010 to 2011)</li>
</ul>
</li>
<li>The Legal 500 United States
<ul>
<li>Recommended in Tax: International Tax (2020 to 2022, 2024)</li>
<li>Recommended in Tax: Not-for-Profit (Fortune 1000 private foundations, national trade associations and charities) (2024)</li>
<li>Recommended in Tax: Contentious (2019 to 2024)</li>
<li>Recommended in Tax: Non-Contentious (2020 to 2024)</li>
<li>Recommended in <span style="line-height: 20.8px;">Tax: Domestic Tax (2015)</span></li>
</ul>
</li>
<li>Lexology Index (formerly Who&#8217;s Who Legal)
<ul>
<li>Corporate Tax (2012 to 2018, 2022 to 2024)</li>
<li>Thought Leaders: Global Elite: Corporate Tax &#8211; Controversy (2023 to 2024)</li>
<li>Thought Leaders: USA: Corporate Tax &#8211; Controversy (2023 to 2025)</li>
</ul>
</li>
<li><em>The Best Lawyers in Americ</em>a<em>®</em> (2005 to 2025)
<ul>
<li>Washington, D.C.: Litigation and Controversy &#8211; Tax</li>
<li>Washington, D.C.: Tax Law</li>
</ul>
</li>
<li>Washington, D.C., &#8220;Super Lawyer&#8221; (2005 to 2020, 2023 to 2024)</li>
<li>Irish Legal 100 (2022 to 2024)</li>
<li>Martindale-Hubbell: AV Preeminent</li>
</ul>


Washington, D.C.

Jeff Paravano Provides Washington Update During Annual Cleveland Tax Institute

Jeff Paravano Authors Article for Tax Notes on Moore Case

Jeff Paravano, Jeremiah Hart, Nicholas Mowbray Author Article for Employee Benefit Plan Review

Jeff Paravano, Jonathan Forster Present at 2024 FFR Tax Institute

Jeff Paravano, Nick Mowbray Speak on Panel at IFA USA Cleveland Regional Event

Jeff Paravano, Andrew Grossman Discuss Moore v. United States on Celesq Webinar

Tax Group

BakerHostetler Services

Jeff Paravano, Michelle Hervey, Nick Mowbray Speak to Tax Club of Cleveland

Prevailing Wage and Apprenticeship Requirements – Analysis of the Final Regulations

Jeff Paravano, Dave Ebersole, Jonathan Drake Present at 2024 Ohio Tax Conference

Lead Tax Attorney on <i>Moore v. United States</i> Serves on Panel for IFA USA Multi-Regional Webinar to Discuss Decision Significance

BakerHosts

Implications of Supreme Court’s Tax Decision in <i>Moore v. United States</i>

Jeff Paravano, Andrew Grossman Discuss Implications of <i>Moore</i> on Taxing Issues Webcast

Supreme Court Decision on <i>Moore v. United States</i> Debated in Media

Counsel of Record for Taxpayers in <i>Moore v. United States</i> Discuss Tax Implications of Supreme Court’s Decision

Lead Tax Counsel in Supreme Court Case <i>Moore v. United States</i> Discusses Federal, State and International Tax Implications for PLI Program

Lead Tax Counsel in <i>Moore v. United States</i> to discuss Federal, State and International Tax Implications of Supreme Court’s Decision

Supreme Court Upholds Mandatory Repatriation Tax but Suggests Wealth Taxes a Step Too Far

Supreme Court Upholds Mandatory Repatriation Tax in Narrow Ruling

Webinar: Implications of the Supreme Court’s Tax Decision in <i>Moore v. United States</i>

BakerHostetler attorneys, practice areas stand out in The Legal 500 annual guide

Proposed Regulations – Clean Electricity Production and Investment Credits (45Y and 48E)

Lead Tax Counsel in <i>Moore v. United States</i> to discuss International Tax Implications of Supreme Court’s Decision

Chambers USA Guide 2024 Recognizes 155 BakerHostetler Attorneys and ­66 Practice Areas

BakerHostetler Sponsors Tax Executives Institute Seminar

D.C. Court of Appeals Strengthens IRS’ Ability to Collect Penalties for Not Reporting Foreign Company Ownership

Five BakerHostetler Attorneys Involved in ABA Section of Taxation 2024 May Tax Meeting

Monetizing Renewable Credits Part II – Final Regulations on Transfers of Renewable Credits

Jeff Paravano, Nick Mowbray Participate in IFA USA Cleveland Regional Event on Economic Substance Doctrine

Eight BakerHostetler Attorneys Named to 2024 Law360 Editorial Advisory Boards

Monetizing Renewable Energy Credits – Final Regulations on Direct Pay

Jeff Paravano, Matt Hunsaker Present at the 2024 TEI Midyear Conference

Jeffrey Paravano Named Who’s Who Legal Thought Leader – Global Elite for 2024

Peter Roskam, Jeff Paravano to Provide Washington Update to Tax Club of Cleveland

Overview of the Proposed Regulations for Advanced Manufacturing Credits Under Section 45X

Paravano, Mowbray and Campbell present at annual Cleveland Tax Institute

Analysis of IRS Proposed Regulations Addressing the Renewable Energy Credit Prevailing Wage and Apprenticeship Requirements

Energy industry seeks change to proposed rule on direct pay of tax credits

Overview of the Proposed Regulations Addressing Transferring Renewable Credits

Supreme Court Agrees to Hear Case Challenging Federal Tax on Unrealized Income

Overview of the Proposed Regulations Addressing Direct Pay

BakerHostetler Attorneys and Practice Areas Recognized in The Legal 500 2023 Guide

Chambers USA Guide 2023 Honors 147 BakerHostetler Attorneys and Recognizes 64 Practice Areas

Jeff Paravano Is Named Notable Tax Practitioner, a Global Recognition of Excellence

Risks Associated with the Purchase of Renewable Energy Credits – Part II

Six BakerHostetler Attorneys Offer Federal Tax Policy and Controversy Program

Jeff Paravano Quoted About Impact of Laws Incentivizing Research and Development

Jeff Paravano Quoted About Payroll Tax Provisions in Fiscal Year 2024 Federal Budget

Supreme Court Rules in Favor of Taxpayer in FBAR Case – Penalty for Non-Willful Violations Apply on a Per-Report Basis

Paul Schmidt, Jeffrey Paravano and Brian Davis Offer Washington Update at Cleveland Tax Institute; Scott Swartz Is Chair of the Event

Jeff Paravano Says Taxpayers Should Not Be Subject to Surprise FBAR Penalties

Jeff Paravano, Poe Leggette and Nicholas Mowbray Explain Energy Tax Credits

What’s in It for Me: The Inflation Reduction Act’s Clean Energy Tax Credits

Jeff Paravano and Mark Tuohey Selected for Irish Legal 100

Jeff Paravano Quoted in Agenda Article on Effects of Buyback Tax

Hundreds of BakerHostetler Attorneys Honored as 2023 Best Lawyers, Ones to Watch and Lawyers of the Year

Inflation Reduction Act Becomes Law

Per-Account or Per-Form Penalty?

BakerHostetler Attorneys, Practice Areas Shine in The Legal 500 2022 Guide

Chambers USA Guide 2022 Honors 145 BakerHostetler Attorneys and Recognizes 62 Practice Areas

Bringing the Past to Life: AAPI Program Recreates Key Moments in American History

BakerHostetler Adds Government Contracts Partner in Washington

Four BakerHostetler Attorneys Recognized in JD Supra Readers’ Choice Awards

Jeffrey Paravano, Mike Ferguson, Jonathan Forster Quoted Regarding Future of Tax Reform

Jeffrey Paravano, Jonathan Forster, Mike Ferguson Lead Webinar on Tax Impact of Build Back Better Plan

Jeffrey Paravano, Alexander Reid, David Ebersole Present on Expected Tax Changes

Edward Bernert, Brian Davis, Jeffrey Paravano, David Ebersole, Nicholas Mowbray are Speakers at Cleveland Tax Institute

Jeffrey Paravano, Brian Davis, Jonathan Forster, Morgan Holtman, James Judd Discuss House Committee Tax Proposals

Jeffrey Paravano Comments on Proposed Bank Tax Reporting Requirement

House and Senate Advance President Biden’s Far-Reaching 2021 Tax Changes

191 BakerHostetler Attorneys Named in 2022 “Best Lawyers” List; 10 Recognized as “Lawyer of the Year”

Virtual Roundtable: Life Goes On In The Tax World

Jeff Paravano, Jonathan Forster Discuss Proposed Tax Reform

BakerHostetler Attorneys, Practice Areas Recognized in The Legal 500 Guide for 2021

Jeff Paravano Comments on Proposed Tax Changes and Potential Effects on Wealth Planning

Biden Budget and Treasury Green Book Add Details to Expected Far-Reaching 2021 Tax Changes

Chambers and Partners USA Honors 134 BakerHostetler Attorneys and 55 Practice Areas in 2021 USA Guide

White House Adds Details to Its Far-Reaching 2021 Tax Reform Plans

2021 Tax Reform Expected to Be Substantial and Far-Reaching

Preparing Your Estate Plan for Biden Administration Tax Changes

Jeffrey Paravano Client Alert Quoted in Article about Deduction Limit on Executive Pay

The Most Important Items in the $1.9T American Rescue Plan Signed Today by President Biden

Preparing for Biden Administration Tax Changes

President Signed Consolidated Appropriations Act that Includes $900 Billion for COVID-19 Relief

$2 Trillion CARES Act Provides Significant Tax and Workforce Relief for Businesses, Individuals

BakerHostetler Attorneys Make Significant Gains in The Legal 500 Annual Guide

Chambers and Partners USA Honors 127 Attorneys and 43 Practice Areas in 2019 Guide

<i>Chambers and Partners USA</i> Honors 118 Attorneys and 45 Practice Areas  in 2018 Guide

150 BakerHostetler Attorneys Named 2016 Super Lawyers; 91 Named Rising Stars

Paravano & Lehrer Address Tax Executives Institute

Paravano & Lehrer Address TEI Houston Chapter “Tax School”

Paravano, Erney & Lehrer Address Tax Executives Institute

Five BH Attorneys Address Tax Institute

Paravano & Lehrer Address International Tax Course

Criminal Tax Defense

Global Capabilities

International Tax

Tax Controversy and Litigation

Tax Credit Controversy

Transactional Tax

Enterprise Issues

Inflation Reduction Act Tax Credits

<h5>Tax Controversy and Tax Litigation</h5>
<ul>
<li>Serves as lead counsel in a more than $100 million Tax Court case filed in January 2024, challenging the validity of an illegal IRS retroactive regulation and IRS alternative Section 482 and economic substance arguments.</li>
<li>Performs a significant amount of large-case controversy work involving both domestic and international tax issues. Has represented numerous clients under audit; at IRS appeals; and in Tax Court, refund and appellate litigation. Was a member of the team that represented a multinational oil company in the U.S. Tax Court, where more than $1.3 billion in tax and interest was at stake with respect to a Section 482 transfer pricing issue alone.</li>
<li>Has assisted, at the audit stage, clients facing several hundred significant issues affecting numerous related corporations located in taxing jurisdictions around the globe. Advises with respect to the merits of particular items and the interrelation of domestic and international tax issues.</li>
<li>Has assisted clients with shortening the examination process by focusing attention on significant issues and resolving issues not warranting litigation; evaluating which adjustments made by teams of IRS agents should be protested to the IRS Office of Appeals; preparing written protests and administrative settlement agreements; obtaining abatement of various types of penalties; obtaining private letter rulings, closing agreements and other forms of IRS national office and field advice; selecting and preparing witnesses and reputable, effective experts; providing advice in disputes over IRS demands for documents and information, including challenges to and defenses against administrative summonses; arguing against the validity of regulations; considering the appropriateness of filing amicus briefs; and selecting and litigating various test cases.</li>
<li>Serves on the BakerHostetler team of court-appointed counsel to the SIPA Trustee for the liquidation of Bernard L. Madoff Investment Securities LLC (BLMIS), working on the $326 million settlement with the IRS in which it was determined that BLMIS falsely debited the accounts of 145 foreign account holders for alleged U.S. federal income tax withholding and paid to the IRS such withheld amounts related to alleged dividends.</li>
<li>Served as a member of the team appointed as counsel to the Tort Claimant’s Committee in the Pacific Gas &amp; Electric bankruptcy cases relating to California wildfires.</li>
<li>Serves as lead tax counsel to several large corporations determining tax consequences from fall-out of alleged $800 million Ponzi scheme involving more than a dozen investors in more than 30 funds that invested in mobile solar generators with DC Solar Solutions, and serves as lead counsel in the only docketed Tax Court case relating to those matters: <em>Solar Eclipse Investment Fund III v. Commissioner</em>.</li>
<li>Serves as lead tax counsel in <em>Moore v. United States</em>, argued before the U.S. Supreme Court on December 5, 2023, regarding the constitutional requirement of realization for federal taxation of income and the validity of the so-called mandatory repatriation tax enacted as part of the Tax Cuts and Jobs Act of 2017.</li>
<li>Served as a member of the team representing 26 state Attorneys General in federal district court that challenged the constitutionality of certain penalty provisions.</li>
</ul>
<h5>Transactional Tax Advice</h5>
<ul>
<li>Assists clients with structuring, negotiating and documenting corporate, partnership and limited liability company formation, as well as merger, acquisition, joint venture, financial and disposition transactions – including spin-off transactions, asset sales, stock sales and Section 338(h)(10) transactions – working closely with clients, investment bankers and the IRS national office, as necessary, and adhering to aggressive timetables in order to maximize client business opportunities.</li>
<li>Has obtained numerous private letter rulings and authored numerous tax opinions covering transactional tax issues.</li>
<li>Has provided post-closing advice to clients with respect to negotiating and arbitrating tax sharing agreement provisions and purchase and sale agreement provisions relating to allocations of tax benefits, refund claims, use of losses, etc., between and among sellers and purchasers.</li>
<li>Assists clients experiencing financial difficulties by developing realistic plans and alternative proposals for restructuring debt and equity, and advises lender and borrower clients in connection with workouts and other capital restructurings.</li>
</ul>
<h5>Tax Shelter Compliance and IRS Promoter Investigations</h5>
<ul>
<li>Regularly provides independent advice to tax directors and board committees with respect to tax minimization strategies proposed by others or developed in-house.</li>
<li>Assists multinational corporations with so-called tax shelter regulation disclosure compliance.</li>
<li>Represents professional service organizations and individuals regarding IRS promoter investigations. Advised one of the largest accounting firms in the United States regarding the strengths and risks associated with certain tax minimization strategies.</li>
<li>Advised a global investment banking firm in connection with the development of procedures and internal controls with respect to tax minimization strategies and transactions affecting book income.</li>
<li>While at the Treasury, worked with IRS officials regarding the development of the first three global settlement initiatives for listed transactions.</li>
</ul>
<h5>International Tax Advice</h5>
<ul>
<li>Assists clients with multifaceted international matters, including structuring inbound and outbound business and real estate investments; cross-border mergers, dispositions and joint ventures; reorganizing and restructuring multinational corporate groups; creating centralized cash management centers; international controversies before the IRS and in the courts; and devising specialized planning involving transfer pricing, foreign entity classification, foreign tax credits, refreshing expiring NOLs, foreign currency transactions, profit repatriations and tax treaty issues.</li>
<li>Serves as lead tax counsel in connection with international arbitration of base erosion and anti-abuse tax (“BEAT”) contract interpretation issues.</li>
<li>Regularly provides advice to clients with respect to global intangible low-taxed income (“GILTI”) and foreign-derived intangible income (“FDII”).</li>
</ul>
<h5>REIT Tax Issues</h5>
<ul>
<li>Has advised a number of publicly traded real estate investment trusts (REITs) and a number of private REITs on an ongoing basis with respect to various issues, including going public, secondary offerings of debt and equity (including use of private REIT structures to raise nearly $1 billion of capital from non-U.S. equity markets), tax compliance and private letter ruling requests, mergers with public REITs, private REITs and non-REITs, UPREIT structures, DownREIT transactions, and structuring and negotiating joint ventures and limited liability company agreements with developers, pension funds, venture capital funds; and other non-REITs.</li>
<li>Acted as tax counsel to the Special Committee of the board of directors of a publicly traded REIT charged with evaluating merger, management buyout and other bids in connection with the auction of the REIT, and as special tax counsel for a number of REITs seeking closing agreements from the IRS regarding REIT qualification issues.</li>
<li>Worked extensively with NAREIT and the Real Estate Round Table with respect to legislative and tax policy issues.</li>
</ul>


Jeffrey H. Paravano

Jeffrey H. Paravano

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