JONATHAN R. FLORA
Partner
Lindquist & Vennum PLLP
Jon concentrates his practice in the following areas:
Tax. Jon provides tax advice and planning for business entities and related individuals. Jon has structured taxable and tax-free acquisitions, mergers, divestitures and spin-off transactions for public and private corporations. He routinely advises clients on partnership and corporate (subchapters C and S) tax issues, and he has organized numerous LLCs, limited partnerships and joint ventures. Jon structures and documents tax-deferred Section 1031 exchanges. He advises litigants on the taxation of settlements and damages awards. In addition to tax planning, Jon prepares tax opinions for transactions, represents clients in seeking private letter rulings, and assists clients in responding to IRS inquiries. Jon is a member of the editorial board of the M&A Tax Report, a monthly publication by CCH Incorporated.
Equipment Finance and Leasing. Jon advises public and privately held companies on documenting, structuring and closing complex lease and financing transactions in a variety of industries. He also advises leasing companies on organizational, tax, UCC and regulatory issues.
Mergers and Acquisitions. Jon has negotiated, documented and closed stock and asset acquisitions in a range of industries for buyers and sellers.
General Business Representation. Jon has organized numerous entities, including corporations, LLCs and limited partnerships, and he frequently advises clients on the appropriate choice of entity. Jon has negotiated and documented a wide range of corporate transactions, including shareholder relations, licensing, financing and consulting agreements. He also counsels on governance issues.
Prior to joining Lindquist, Jon practiced in Seattle, Washington, and in San Francisco and San Diego, California.
Education:
New York University School of Law (LL.M., taxation)
University of Maryland School of Law (J.D., articles editor, Maryland Law
Review, order of the coif)
University of California-Davis (M.A.)
Admissions:
California
District of Columbia
Minnesota
Washington
U.S. District Court for Southern, Central Districts of California
U.S.
Tax Court
Legal Memberships:
Minnesota State Bar Association
California State Bar Association
Washington State Bar Association
American Bar Association, Taxation Section, Real Estate Committee
Publications:
How Escrowed Stock Impacts Continuity of Interest: The Continuing Saga (The M&A Tax Report Vol. 13, No. 11, p. 1) June 2005
Book Review: Taxation of Damage Awards and Settlements (The M&A Tax Report, Vol. 13, No. 9, p.5) April 2005
New Regs Let Taxpayers Turn Off the Step Doctrine (Tax Notes at 103) Aug. 25, 2003
COD Income, Reporting, and Injustice (Or, How the IRS Makes You Pay Taxes On Income You Don't Have) (The M&A Tax Report, Vol. 11, No. 6, p. 1) January 2003
Beating the Hobby Loss Rule: Is it Possible to Sell Amway for Profit? (Tax Notes, Feb. 10, 2003, at 970, and published in California Tax Lawyer, v. 11, no. 5) Fall 2002
ISOs and Section 83(b) Elections (The M&A Tax Report, v. 11, no.3), with Robert Wood, October 2002
New (Final!) Form 1099 Reporting Regs: Attorneys' Fee Regs in Drag?, (97 Tax Notes 265), with Robert Wood, Oct. 14, 2002
Basics of Accounting: Do the Numbers Lie? (The M&A Tax Report, v. 11, no. 2) September 2002
Fior D'Italia: One Reason to Watch Your Stipulation of Facts (California Tax Network, p. 6) August 2002
Can Mergers Merit Tax Shelter Penalties? (The M&A Tax Report, v. 10, no. 11) June 2002
Presentations:
Taxation of Litigation Payments, National Business Institute (May 2004)
Tax Aspects of Damage Awards & Settlements, California State Bar Winter Section Education Institute (January 2003)
Section 1031 Exchanges of Investment Property in Washington, National Business Institute (March 2002)