- Tax AlertMay 24, 2018
John J. Eagan Partner
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John Eagan is a partner in the Business Department. He focuses his practice on taxation matters, with particular emphasis on planning for U.S. and international business clients. John provides business tax counseling and planning on a variety of issues, including business entity transactional work (mergers and acquisitions and corporate reorganizations), business and tax structures for foreign investment in the U.S. (organizational and investment structures, FIRPTA, transfer pricing, branch profits, repatriation and treaty issues), 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 125 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 U.S. Tax Court, and U.S. District Court with regard to a wide variety of tax audits 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. John also has expertise 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.
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.
Represented a data analytics company that provides proprietary consumer intelligence to major luxury brands in its sale to a global communications agency.
- Advised the strategic investment arm of a life and disability insurer in connection with an investment in a special purpose acquisition vehicle which acquired a controlling interest in a provider of trade credit risk management technology solutions
- Represented an IT services business in connection with a joint venture with a U.S. based private equity firm
- Counseled the strategic investment arm of a life and disability insurer through a Series C preferred equity round for a co-working space company
- Represented a UK company on U.S. tax aspects of the sale of its business to a German public company
- Represented a flavors and fragrance company in connection with a Code Section 338(h)(10) sale to a Swiss-based fragrance business
- Advised numerous clients on Federal, state, and local tax issues for acquisitions, divestitures, spin-offs and reorganizations involving U.S. and international businesses
- Advised on tax and structuring issues related to joint venture investments in multiple countries
- Advised clients on inbound investment in the U.S., including tax treaty issues
- Obtained private letter rulings from the IRS on for profit and tax-exempt issues in order to facilitate business transactions
- Represented clients in Federal and state tax audits, often resulting in little or no tax deficiency
- Successfully litigated and settled cases in the U.S. Tax Court involving substantial proposed assessments on a variety of domestic and international tax issues
- Represented clients in becoming compliant with unreported offshore bank accounts under the IRS Offshore Voluntary Disclosure Program
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 magazine from 2013 through 2017.
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.
- November 11, 2017
- October 18, 2016
- October 21, 2015
- October 22, 2014
- Super Lawyers MagazineSeptember 13, 2013
- December 17, 2012
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- IRS Issues Interim Guidance for Foreign Bank and Financial Accounts Penalties; Congress Changes Deadline for FilingTax AlertAugust 17, 2015
- Tax and M&A AlertJune 3, 2015
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Cases & Deals
- February 23, 2018
- October 20, 2017
- June 1, 2017
- May 4, 2017
- January 31, 2017
- January 12, 2017
- December 15, 2016
- November 3, 2016
- July 25, 2016
- October 23, 2015
- January 21, 2015
- December 1, 2014
- July 28, 2014
- March 21, 2014
- November 8, 2013
- September 27, 2013