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Ron G. Nardini
Ron G. Nardini
Partner — Tax
Partner — Tax

Ron G. Nardini

Ron G. Nardini
New York

The Grace Building
1114 Avenue of the Americas
32nd Floor
New York, NY 10036

Ron G. Nardini

Experience Highlights

  • Client in the acquisition of a public energy company valued in excess of $9 billion

  • A large financial services company in its utilization of a significant net operating loss carryover

  • Government of Japan with respect to a tax-strategy research project

  • Real estate group in the formation of a real estate platform attractive to sovereign wealth funds and other non-U.S. investors

  • Investment funds formed for the purposes of investing in contingent future cash flows generated from pharmaceutical, musical or film royalties

  • Investment funds formed for the purposes of investing in loan origination

  • Various joint ventures in shipping and aircraft investments

  • Investment fund in investments in a portfolio of life insurance policies

  • Large multinationals in the relocation of their corporate headquarters to or from the United States, cross-border licensing, cost-sharing agreements and other international tax issues

Credentials

  • New York University School of Law, LL.M., 2002
  • Tel Aviv University School of Law, LL.B. magna cum laude, 2000
  • Tel Aviv University, B.A. Accounting magna cum laude, 2000
  • Selected for Turnarounds & Workouts’ Top Bankruptcy Tax Specialists list, 2020
  • New York
  • Israel (inactive)
  • Hebrew, fluent
  • “Certain Tax Considerations for Secondary Transfers of Private Equity Fund Interests (Secondaries),” Private Investment Fund Tax Master Class, May 2020 (panelist)
  • “Unpack Recent Guidance on Qualified Opportunity Zones (QOZ),” FRA Private Investment Fund Tax & Accounting Forum, November 2019 (speaker)
  • “Private Equity Deal Structures following TCJA,” Private Investment Fund Tax and Accounting Master Class, May 2019 (panelist)
  • “The Opportunity Zone Investment Tax Regime: Recent Legislative and Regulatory Developments You Should Know,” The Knowledge Group Webcast, April 2019 (speaker)
  • “Funds Update,” 8th Annual IBA Finance & Capital Markets Tax Conference, January 2019 (panelist)
  • “Are You in the Zone? An Overview and Case Study of the New Opportunity Zone Program,” January 2019 (panelist)
  • “Fund and Portfolio Company Operations in Light of the New Tax Act,” Private Investment Fund Tax Master Class, May 2018 (panelist)
  • “U.S. Withholding on Synthetic Trades over U.S. Equities (Section 871(m)) – Additional Delay of Full Implementation until 2023,” client alert, December 18, 2019 (co-author)
  • “BBA Tax Audits: Final Deadline for Designating a U.S. Partnership Representative,” client alert, Aug 26, 2019 (co-author)
  • “Latest Opportunity Zone Rules Clarify Issues Related to Fund Structuring, Qualifying Businesses and Business Property,” client alert, May 24, 2019 (co-author)
  • “Considerations for Asian Fund Managers Under the U.S. New Partnership Audit Regime,” Journal of Investment Compliance, Vol. 19, No. 3, October 24, 2018 (co-author)
  • “Opportunity Zones: New Guidance Sheds Light on How Private Equity Industry Can Take Advantage,” client alert, October 24, 2018 (co-author)
  • “To Partner or Not to Partner—It’s an Exemption Question,” Taxation of Exempts (Thomson Reuters), March/April 2018 (co-author)
  • “Carried Interest and Other Tax Reform Highlights for Investment Funds and Asset Managers,” client alert, November 7, 2017 (co-author)
  • “Comprehensive Overhaul of Partnership Audit Regime,” client alert, November 11, 2015 (co-author)
  • “IRS Internal Memorandum Advises That Self-Employment Tax Applies to Profits From an Investment Manager,” client alert, September 10, 2014 (co-author)
  • “Stampeding for the Exits: Pharmaceutical Companies and the Recent Wave of Inversions,” blog post, Jul 21, 2014 (co-author)
  • “Treasury Issues Temporary and Proposed Regulations on Dividend Equivalent Payments,” February 1, 2012 (co-author)
  • “Latest Opportunity Zone Rules Significantly Expand Types of Qualifying Investments,” May 6, 2010 (co-author)