Angelika Nazarenko

Associate

Washington + 1.202.879.4660

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Angelika Nazarenko advises clients on tax planning, corporate restructuring, and tax consequences arising in M&A transactions. She regularly counsels clients on tax implications of private and public acquisitions and negotiates tax-related provisions in transaction documents to secure the most tax-efficient results for clients. She also assists clients with tax-related disclosure obligations in Securities and Exchange Commission (SEC) filings such as Form 10-K, Form S-4, and other similar disclosures. Additionally, Angelika frequently counsels clients regarding tax provisions in the One Big Beautiful Bill Act of 2025 (known as the OBBBA).

Angelika's practice encompasses the application of complex international tax provisions, including the Foreign Investment in Real Property Tax Act (FIRPTA), branch profits tax, Net CFC Tested Income (formerly known as GILTI), foreign tax credits, base erosion and anti-abuse tax (BEAT), and other cross-border tax regimes. She brings a client-focused approach to every engagement, prioritizing practical solutions tailored to each client's objectives. Angelika has conducted extensive legal research and analysis on the implications of the Tax Cuts and Jobs Act of 2017 (known as TCJA), particularly as it relates to the participation exemption, section 965 inclusions, GILTI, and other international tax provisions of the Internal Revenue Code, as well as the implications of more recent changes in U.S. domestic and international tax rules implemented by the OBBBA.

Erfahrung

  • Saputo divests majority stake in Argentina operationsJones Day advised Saputo Inc. (TSX: SAP) in the sale of a majority interest in its Argentina dairy division to Gloria Foods, the dairy and food holding company of Grupo Gloria, at an enterprise value of $630 million.
  • Open Lending enters into merger agreement to be acquired by ANVJones Day is advising Open Lending Corporation, a leading provider of insurance-backed lending enablement and risk analytics solutions for financial institutions, in its acquisition by ANV Group Holdings Ltd., a global insurance intermediary platform, for $3.15 per share through an all-cash tender offer.
  • Bora Pharmaceuticals acquires MacroGenics, Inc.'s GMP manufacturing operationsJones Day represented Bora Pharmaceuticals Co., Ltd. in its acquisition of the GMP manufacturing operations, including the CDMO business, of MacroGenics, Inc. (Nasdaq: MGNX) for $122.5 million cash.
  • SAP acquires ReltioJones Day advised SAP SE on the acquisition of Reltio, Inc., a leading master data management (MDM) software provider, to help customers make their SAP and non-SAP enterprise data AI-ready.
  • BioMarin acquires Amicus Therapeutics for $4.8 billionJones Day advised BioMarin Pharmaceutical Inc. (Nasdaq: BMRN) in its $4.8 billion acquisition of Amicus Therapeutics (Nasdaq: FOLD).
  • KKR-majority owned OneStream agrees to sell to HgJones Day represented KKR, in its capacity as the holder of a majority of OneStream, Inc’s voting power, in connection with the acquisition of OneStream by Hg, General Atlantic and Tidemark in an all-cash transaction that values OneStream at approximately $6.4 billion.
  • Axiom Partners sells Circle8 to Atlantic InternationalJones Day advised Axiom Partners and Circle8 Group on the sale of all shares in Circle8 Group to Atlantic International Corp (NASDAQ: ATLN) in an all-stock transaction resulting in Axiom or its designated affiliate holding a majority stake in Atlantic International Corp.
  • Embraer acquires manufacturing assets from Safran Cabin in Mexico and BrazilJones Day is advising Embraer S.A., a global aircraft manufacturer, in the acquisition of Safran Cabin's 50% share in EZAir, Safran's 50/50 joint venture that manufactures Embraer's interiors in Chihuahua, Mexico, along with associated aftermarket activities, as well as responsibility for related activities (engineering and manufacturing) in Brazil.
  • TRG sells company to Gemspring CapitalJones Day advised Technology Recovery Group Ltd. (TRG), a leading provider of technology lifecycle management solutions focused on enterprise mobility, in the sale of the company to Gemspring Capital.
  • Bristol Myers Squibb acquires Orbital TherapeuticsJones Day acted as Tax counsel to Bristol Myers Squibb in its $1.5 billion acquisition of Orbital Therapeutics, a privately held biotechnology company pioneering a new generation of RNA medicines that reprogram the immune system in vivo, enabling treatments that provide the precision, control, and flexibility needed to address the underlying biology and unique complexities of each disease.
  • DecisionHR sells majority stake to Coalesce CapitalJones Day advised DecisionHR in the sale of a majority stake to Coalesce Capital Partners, a private equity firm focused on investing in human capital-driven and technology-enabled services companies.
  • HanesBrands and Gildan agree to combine to create a global basic apparel leaderJones Day advised Hanesbrands Inc. in the $2.2 billion acquisition of Hanesbrands by Gildan Activewear Inc.
  • Koch subsidiary acquires Anchor PackagingJones Day advised Koch, Inc. in the acquisition by subsidiary, Georgia Pacific, of Anchor Packaging, a leading manufacturer of rigid food containers and cling film for the food service, retail and processor channels, from TJC (formerly known as The Jordan Company), a New York City-based private equity firm.
  • Bristol Myers Squibb and Bain Capital create new company dedicated to developing innovative immunology therapiesJones Day acted as tax counsel to Bristol Myers Squibb in the creation of a new independent biopharmaceutical company with Bain Capital focused on developing new therapies for autoimmune diseases that address significant unmet needs of patients.
  • Bristol Myers Squibb and BioNTech announce global strategic partnership to co-develop and co-commercialize next-generation bispecific antibody candidate BNT327 broadly for multiple solid tumor typesJones Day acted as tax counsel to Bristol Myers Squibb in the agreement with BioNTech SE for the global co-development and co-commercialization of BioNTech’s investigational bispecific antibody BNT327 across numerous solid tumor types. Under the agreement, BioNTech and BMS will work jointly to broaden and accelerate the development of this clinical candidate.
  • EagleTree Capital makes strategic investment in NuTrailJones Day advised EagleTree Capital in its strategic investment in NuTrail, a leading nut-based granola brand.
  • Bristol Myers Squibb acquires 2seventy bioJones Day acted as Tax counsel to Bristol Myers Squibb in the $286 million merger with 2seventy bio.
  • Delaware North completes business combination and debt financing transaction of its Illinois Route-Gaming businessJones Day advised Delaware North in the business combination transaction of its route-gaming business in Illinois with Eureka Entertainment's Universal Gaming Group.
  • Hub Group forms joint venture with EASOJones Day advised Hub Group, Inc. in the formation of a joint venture with Mexico-based EASO.
  • STERIS enters into replacement $1.1 billion revolving credit facilityJones Day represented STERIS plc and its affiliates in connection with a replacement $1.1 billion revolving credit facility with JPMorgan Chase Bank, N.A., as administrative agent.
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