Jon Nelsen focuses on federal income tax matters. His practice includes planning mergers, acquisitions, reorganizations, joint ventures, and transactions involving major energy companies and master limited partnerships and representing large companies and high net worth individuals in tax controversy matters nationwide.
Mr. Nelsen's extensive tax planning practice includes advising major energy companies on complex mergers and acquisitions involving a broad range of tax issues, including Section 338(h)(10) elections, qualification for reorganization treatment, and planning for post-acquisition matters. He also advises publicly traded partnerships on formation issues, initial public offerings, dropdown transactions, qualifying income planning, and follow-on offerings. He regularly advises utilities, oil and gas, and energy companies on planning and effecting mergers and acquisitions, normalization considerations, and utilizing alternative energy tax incentives, including production and incentive tax credits.
Mr. Nelsen's controversy experience includes representing clients in IRS examinations, appeals, fast track mediations, post-Appeals mediation, and pre-filing agreement negotiations. These matters relate to numerous areas of federal income taxation, including energy and oil and gas tax issues, financial products issues, debt vs. equity issues, depreciation issues, research and development credit issues, casualty loss issues, section 1033 issues, and normalization issues. Mr. Nelsen also has extensive experience advising large companies with respect to competent authority matters, FIN 48 issues, Schedule UTP, working with outside auditors, and financial disclosure issues.