John J. Eagan Partner

John Eagan is a partner in the Business Department. He focuses his practice on taxation matters, with particular emphasis on planning for US and international business clients. John provides business tax counseling and planning on a variety of issues, including business entity transactional work (mergers, acquisitions, structures and reorganizations), business and tax structures for foreign investment in the US (business formation and investment structures, FIRPTA, transfer pricing, branch profits, repatriation and treaty issues), outbound structuring (including controlled foreign corporation issues), and S corporation, partnership, and limited liability company taxation. 

John’s focus is on strong client communication with the goal of creating clarity from the complexity of business transactions. His matters are handled in a practical and cost-effective manner consistent with the client’s business needs and objectives.

John has significant transactional experience, having represented clients in more than 150 transactions in a variety of industries, and he works to develop effective planning approaches to minimize taxation. John has represented clients before state taxing authorities, the Internal Revenue Service, the US Tax Court, and US District Court with regard to a wide variety of tax audits, appeals conferences, and litigation, including international tax audits, transfer pricing issues, spin-off and reorganization issues, refund litigation, treaty interpretation, corporate tax assessments, trust fund liability, sales and use taxation, state income tax allocation and apportionment issues, debt restructuring, and excise taxation and offers in compromise. John also has substantial experience in reporting issues for offshore accounts, including submissions to the Internal Revenue Service under the Offshore Voluntary Disclosure Programs and the Streamlined Filing Compliance Procedures Program, as well as advising clients on tax-exemption issues.

John has handled numerous IRS and state taxation audits, and he has substantial experience in resolving cases at the administrative level in a creative manner. 

Representative Matters

• Advised multiple clients on part sale/part rollover equity transactions
• Represented clients in profits interest transactions and deferred equity grants
• Redomesticated a Delaware limited liability company to the Cayman Islands under the recently enacted Limited Liability Companies Law
• Advised multiple non-US companies on investment structures for US expansion

• Represented a data analytics company that provides proprietary consumer intelligence to major luxury brands in its sale to a global communications agency

Recognition & Involvement

John has been selected for inclusion in ”Super Lawyers” in the New York Metro Region in a survey of his peers by Super Lawyers from 2013 through 2018.

John has long had an interest in law firm management issues. He co-founded a managing partner discussion group in New Jersey and participates in a similar group in New York City.

John is active in the New Jersey State Bar Association and he organized a new subcommittee of the Taxation Section on international tax issues.