Jon B. Nelsen

Since joining Kirkland, Jon has been involved in the following matters:

• Arroyo Investors—in its sale of ARCO, one of the largest independent renewable power producers in Chile, to Sonnedix, a global renewable energy independent power producer
• Major global financial institution—application of FATCA rules and treaties before US governmental bodies
• Major energy company—case before IRS Exam on origin of the claim issues flowing from litigation resolution
• Numerous private foundations—application of excise tax rules
• RedTeam Software, LLC, a construction management software provider—acquisition of PASKR Inc., a cloud-based construction management solution

Prior to joining Kirkland, Jon was involved in the following matters:

Tax Litigation/Controversy

• Major energy company—competent authority and MAP negotiations
• Real estate investment company—case before IRS Appeals involving a complete IRS concession on debt vs. equity issue
• Bank holding company—case before IRS Appeals on bad debt deduction
• Major E&P company—case before IRS Appeals on application of straddle and interest capitalization rules
• Major E&P company—fast track mediation with IRS Exam and IRS Appeals on application of bonus depreciation rules
• Major oil field services company—case before IRS Appeals on research and development credit issues
• Major energy company—case before IRS Appeals on oil and gas hedging issue
• Industry leader—post appeals mediation relating to scope of Section 172(f)
• Major receivership—handled federal tax issues related to receivership proceeding
• Major telecommunications company—fast track mediation on application of straddle and interest capitalization rules
• Major energy company—representation throughout audit process before IRS Exam and IRS Appeals with respect to a range of issues, including casualty loss deductibility
• Major utility—contested rate cases before the Texas Public Utility Commission relating to complex tax issues
• Leading education company—Section 1033 issues

Tax Partnerships

• Major commercial real estate developer—complex partnership arrangements and restructurings
• Real estate investment company—numerous complex joint ventures
• NYSE-listed oil and gas company—formation of an approximately $3.5 billion midstream natural gas pipeline joint venture
• Wind turbine manufac urer—joint venture with operator to take advantage of Treasury grants
• Wind energy investor—joint venture with operator to take advantage of state and Treasury grants
• Leading energy investment private equity firm—numerous engagements in the purchase of offshore pipelines, the purchase of membership interests in a pipeline joint venture, the purchase of natural gas and solid-fuel generation facilities, and the formation of a joint venture with a leading midstream energy company
• Midstream master limited partnership—initial public offering

Mergers & Acquisitions

• Major utility—acquisitions of numerous renewable energy projects
• Major utility—advised as to potential acquisition of another utility involving Section 338(h)(10) election considerations
• Large independent E&P company—acquisition of oil and gas assets
• Large independent E&P company—sale of oil and gas assets
• Major energy company—acquisition of cogeneration facility
• Major energy company—acquisition of customer contracts and limited liability company
• Technology company—sale of company involving complex Section 338(h)(10) considerations
• Leading energy services company—numerous acquisitions

Alternative Energy

• Major solar developer—implementation of residential lease facility
• Major manufacturer—advice as to the availability of production tax credits, investment tax credits, and Treasury Grants for producing electricity from landfill gas facilities
• Major utility—assisted in obtaining Smart Grid grants
• Solar lease provider—structuring to claim Treasury Grants

Partner, Armbrust & Brown PLLC, 2021

Partner, Baker Botts LLP, 2006–2021