Jonathan (J.J.) Gifford’s practice focuses on taxation and related matters.
He advises on U.S. federal income tax controversies, M&A transactions, and corporate and partnership planning.
J.J. joined the firm in 2006, and became senior attorney in 2013 and counsel in 2019.
Veolia Environnement S.A. in its successful defense of an Internal Revenue Service audit of a multibillion-dollar worthless stock deduction, including a series of court proceedings defending the taxpayer’s privilege claims that were resolved substantially in the taxpayer’s favor.
McDonald’s in the sale of its Chinese operations to CITIC and Carlyle, and in related master franchise agreements, as part of a strategic partnership to expand in mainland China and Hong Kong.
OpenText Corp. in numerous acquisitions, including its $1.62 billion acquisition of Dell EMC’s Enterprise Content Division and acquisition of Guidance Software Inc.
TPG in the formation of The Rise Fund, a social impact private equity fund.
OCI in the proposed $8 billion agreement to combine its North American, European, and Global Distribution businesses with CF Industries in an inversion transaction that was ultimately abandoned.
Harland Clarke (a MacAndrews & Forbes portfolio company) in multiple financing matters, including acquisition financing for MaxPoint Interactive.
HCA Healthcare in its $2 billion registered offering of senior unsecured notes.
Asahi Kasei Corp. in its $2.2 billion acquisition of Polypore International Inc. and subsequent sale of its Separations Media segment to 3M Co. for $1 billion.
Brightstar Corp. and its founder in the $1.26 billion acquisition of a majority interest in Brightstar by Softbank.
Envision Pharmaceuticals (a TPG portfolio company) in its $2 billion sale to Rite Aid Corp., and previously in Envision’s acquisition of Laker Software.
Suntory Holdings Ltd. in its $16 billion acquisition of Beam.
Pall Corp. in connection with its publicly announced restatement of multiple years of financial statements relating to more than $135 million in potential tax liability, and associated tax audit issues.