Biography
James D. Reardon joined Kelly Hart & Hallman in 2004 as a partner and Head of the Tax practice group. Mr. Reardon specializes in corporate income taxation and personal income taxation with respect to investment income. He also has extensive experience in the tax aspects of mergers and acquisitions, business reorganizations, international transactions, venture capital partnerships, financial products and derivatives, equipment leasing, tax controversies, and federal income taxation of trusts and estates. His clients have included commercial banks, investment banks, mutual funds, and energy companies.
In addition to his law practice, Mr. Reardon�s professional activities include numerous publications concerning aspects of financial products, United States federal income tax issues, and international business matters.
Mr. Reardon and his wife, Heather, welcomed their first child, Alex, into their lives in April of 2006. When not otherwise balancing the rewards and risks of raising a newborn, Mr. Reardon enjoys skiing and reading histories and biographies.
Education & Honors
Georgetown University, A.B., 1987
Boston College Law School, J.D., 1991
Universidad Pompeu Fabra, Barcelona, Spain, L.L.M., in corporate law and taxation, 1994
New York University Law School, L.L.M., in taxation, 1996
Admission & Affiliations
Connecticut, 1991
New York, 1992
Washington, D.C., 1993
Massachusetts, 1994
Texas, 2005
New York State Bar Association Tax Section
Significant Matters
Represented large media/communications client in obtaining an IRS private letter ruling to complete a tax-free spin-off of a television business
Represented major power company in sale/leaseback of its co-generation business
Negotiated financial instruments with New York investment bank on behalf of billion-dollar hedge fund
Represented oil field service company in multiple acquisitions of businesses in the same market segment
Formed family limited partnership as investment vehicle on behalf of various clients
Represented major pharmaceutical company in international mergers and acquisitions
Publications & Speeches
Marrita Murphy: The Flip Side of the Economic Substance Doctrine, Tax Notes (September 25, 2006)
Constitutional Implications of the Senate�s Proposal to Codify the Economic Substance Doctrine, 5 Taxation of Financial Products 19, (2004)
Enron Bankruptcy: What Went Wrong, 4 Derivatives & Financial Instruments 158 (2002)
Offshore Hedge Funds - Doing Business in the United States, 15 Journal of Taxation of Financial Institutions 19 (2001)
Casting Light on Investment Funds and Fiscal Secrecy, 3 Derivatives & Financial Instruments 199 (2001)
When is a Derivative Treated as Debt for U. S. Federal Income Tax Purposes?, 3 Derivatives & Financial Instruments 62 (2001)
Source Rules With Respect to the Sale of a Partnership Interest, 2 Derivatives & Financial Instruments 289 (2000)
Angulo & Reardon, The Political and Administrative Expediency Exception Established by the Supreme Court in United States v. Humberto Alvarez Machain to the Rule of Law as Reflected by Recognized Principles of International Law, XIV B.C. Int�l & Comp. L.Rev. 245 (1993)
Bufete Cuatrecasas, Business Law Guide to Spain (Bronhein & Reardon trans., CCH Editions, ed., 1994) |