Ron G. Nardini
The Grace Building
1114 Avenue of the Americas
32nd Floor
New York, New York 10036
Ron G. Nardini advises a broad base of clients on domestic and international tax matters. He focuses primarily on the formation, operation, and investments of private equity, venture capital, and hedge funds, with a particular focus on credit, health care, entertainment and cross-border investments.
In particular, Ron provides tax advice regarding the structuring of investment funds formed to invest in the credit space, including loan origination, trade claims, distressed debt, nonperforming loans, rescue, bridge and debtor-in-possession financing and structured credit.
Ron also advises on the formation of investment managers, the structuring of seed investments, real estate investments, as well as partnership tax matters, mergers and acquisitions, international tax matters and restructurings matters.
Ron has broad understanding of the tax issues attributable to investments by sovereign wealth funds in the U.S. equity and debt markets. In addition, Ron works closely with purchasers and investment funds regarding fund secondary transactions. Finally, Ron works with creditors of financially troubled companies on a variety of tax issues attributable to their investment, including utilization of net operating losses.
Ron is recognized in New York as a Band 5 attorney in Tax by Chambers USA 2023.
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
- Chambers USA, Tax (New York), 2022 and 2023
- Legal 500 U.S., Tax: International Tax, 2022 and 2023; Tax: U.S. Taxes: Non-Contentious, 2022 and 2023
- Selected for Turnarounds & Workouts’ Top Bankruptcy Tax Specialists list, 2020
- New York
- Israel (inactive)
- Hebrew, fluent
- Rankings & AwardsMarch 14, 2024
- Deals & CasesMarch 6, 2024
- Deals & CasesFebruary 21, 2024
- Rankings & AwardsJune 12, 2023
- Rankings & AwardsJune 1, 2023
- Deals & CasesJune 1, 2023
- Deals & CasesJune 1, 2023
- Deals & CasesMay 11, 2023
- InsightJanuary 17, 2023
V&E REIT Update
- Deals & CasesOctober 17, 2022
- Deals & CasesJuly 5, 2022
- Deals & CasesJune 17, 2022
- Rankings & AwardsJune 16, 2022
- Rankings & AwardsJune 1, 2022
- “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)