Jennifer A. Ray is a counsel in the Tax Group in the firm's Washington D.C. office.
Jen advises clients, including public and private companies, investment funds, and tax-exempt entities, on tax aspects of corporate and partnership transactions, including mergers, acquisitions, joint ventures, and debt and equity financings. She works with clients in several industries, including financial services, aerospace, and government contracting.
A large part of Jen's practice relates to structuring of pass-through entities such as partnerships, LLCs, and S corporations. She has extensive experience drafting LLC and partnership agreements, including "safe harbor" and "targeted capital account" agreements for joint ventures and funds, and structuring of "profits interest" or "carried interest" arrangements. Jen advises clients on disguised sale, deemed partnership, and similar issues that arise in connection with transactions.
Jen frequently counsels clients in connection with "inbound" investments into the United States, including whether income is effectively connected with the conduct of a trade or business and the impact of various tax treaties. She also has significant experience advising clients with respect to dual consolidated loss issues arising from cross-border joint ventures and restructuring of foreign entities.
In connection with corporate transactions, Jen analyzes incentive compensation issues, including issues arising under Code sections 280G and 409A, and structures compensation arrangements.