LoriHellkamp

Partner

Washington + 1.202.879.3787

Lori Hellkamp provides commercial solutions to complex tax issues by taking a creative and practical approach to problem solving. Her practice spans a broad range of areas, including corporate and international tax, M&A, and tax controversy. Lori's practice has a particular emphasis on international tax planning, counseling, and compliance as well as tax-efficient structures for cross-border transactions and restructurings. Lori has extensive experience with the issues arising from foreign (inbound) investments into the United States, including in real estate and renewable energy investments.

Lori has counseled public and private companies facing a wide variety of multijurisdictional tax issues, both internally and before the Internal Revenue Service. She has helped clients obtain favorable private letter rulings and advance pricing agreements, resolve disputes at Appeals and in Competent Authority proceedings, and navigate complex tax treaty, transfer pricing, virtual currency, FIRPTA (Foreign Investment in Real Property Tax Act), anti-boycott, and U.S. tax reform issues.

Lori is an active member of the American Bar Association's Tax Section (vice-chair of the US Activities of Foreigners & Tax Treaties Committee) and D.C. Bar Association's Tax Section and frequently speaks and writes on a variety of tax topics. She is also a member of the board for the George Washington University-IRS International Annual Tax Institute and a member of the Jones Day Washington Office's Recruiting Committee.

Experience

  • Citigroup Global Markets acts as lead underwriter on $2.5 billion Senior Unsecured Notes offering by eBay Inc.Jones Day represented Citigroup Global Markets Inc. and the other underwriters, in connection with eBay’s registered offering of (i) $750 million aggregate principal amount of its 1.400% Notes due 2026, (ii) $750 million aggregate principal amount of its 2.600% Notes due 2031 and, (iii) $1.0 billion aggregate principal amount of its 3.650% Notes due 2051.
  • Skyworks Solutions to acquire Infrastructure and Automotive business of Silicon Laboratories for $2.75 billionJones Day is advising Skyworks Solutions, Inc., an innovator of high-performance analog semiconductors, in connection with its definitive agreement to acquire the Infrastructure and Automotive business of Silicon Laboratories Inc. (NASDAQ: SLAB), a leading provider of silicon, software, and solutions, in an all-cash asset transaction valued at $2.75 billion.
  • Medifast obtains $125 million revolving credit facilityJones Day represented Medifast, Inc., an American nutrition and weight loss company, in connection with a $125 million senior secured revolving credit facility with Citibank, N.A., as administrative agent.
  • American Pacific Group acquires Fresche SolutionsJones Day advised American Pacific Group, a San Francisco-based private equity firm, in its acquisition with Northstar Capital of Fresche Solutions, a leading provider of digital transformation and application modernization solutions.
  • Sotera Health acquires Canadian-based Iotron IndustriesJones Day advised Sotera Health in the acquisition of Canadian-based Iotron Industries, a global leader in electron-based sterilization and materials modifications.
  • Junshi and Lilly to develop and commercialize antibodies for prevention and treatment of COVID-19 coronavirusJones Day represented Shanghai Junshi Biosciences Co., Ltd. in its strategic collaboration and license agreement with Eli Lilly and Company for the development, manufacturing, and commercialization of two antibodies for the prevention and treatment of the COVID-19 SARS-CoV-2 novel coronavirus.
  • JTC acquires NES Financial for up to $116 millionJones Day advised JTC PLC in the acquisition of NES Financial, a technology-enabled provider of specialist fund administration and treasury services recognized on the San Francisco Business Times top Bay Area fintech list, for up to $116 million.
  • Benitec Biopharma redomiciled to U.S.Jones Day advised Benitec Biopharma Limited (ASX and NASDAQ listed) ("Benitec Australia") in its redomiciliation from Australia to the U.S. pursuant to a statutory scheme of arrangement under Australian law (the "Scheme").
  • Rising Point Capital acquires Conco HoldingsJones Day advised Rising Point Capital, LLC in its acquisition of Conco Holdings, a provider of low-pressure, mechanical heat exchanger tube cleaning and non-destructive testing services.
  • Hitachi Vantara acquires ContainerShip, Inc.Jones Day advised Hitachi Vantara LLC in its acquisition of assets from ContainerShip, Inc., a start-up company specializing in the Kubernetes open-source platform space.
  • Tinubu® Square acquires U.S. company eSURETY®Jones Day advised Tinubu® Square in its acquisition of U.S.-based eSURETY®, a cloud-based specialty software provider, enabling carriers, brokers, and MGAs to securely apply, quote, bond, issue, and support every form of surety as well as offering a powerful direct-to-the-consumer experience on any device from any browser, anywhere in the world.
  • Huntington Ingalls to sell San Diego Shipyard to Titan Acquisition HoldingsJones Day is advising Huntington Ingalls Industries in the sale of its San Diego Shipyard to Titan Acquisition Holdings.
  • Pemberton Asset Management Group and Permira Debt Managers Limited provide significant unitranche financing for acquisition of Euro Techno Com GroupJones Day represented Pemberton Asset Management Group and Permira Debt Managers Limited in connection with a significant unitranche financing for the acquisition of the Euro Techno Com Group ("ETC"), a distributor of equipment and supplies for the telecommunications market, by Carlyle European Technology Partners.
  • Family Investment Group acquires Propex Operating Company LLC’s furnishings business in U.S.Jones Day advised the Family Investment Group in connection with its acquisition of Propex Operating Company LLC’s furnishings business in the U.S.
  • Family Investment Group acquires controlling interest in Propex Furnishing SolutionsJones Day advised the Family Investment Group in connection with its acquisition of a controlling interest in Propex Operating Company LLC’s European operations, which will be renamed Propex Furnishing Solutions.
  • Total invests in Clean Energy Fuels Corp.Jones Day represented Total S.A., a French multinational integrated oil and gas company, in connection with its purchase of 25 percent of Clean Energy Fuels Corp., a leading provider of natural gas fuel and renewable natural gas fuel for transportation in North America, for $83.4 million, and the credit support to be provided by Total of up to $100 million.
  • Southern Company sells Pivotal Home Solutions to American Water Works Company, Inc. for $363.7 millionJones Day advised Southern Company in the $363.7 million sale of its subsidiary Nicor Energy Services Company (d/b/a Pivotal Home Solutions) to American Water Works Company, Inc.
  • Patrón Tequila acquired by BacardiJones Day advised Patrón Spirits International AG ("Patrón") in connection with the acquisition by Bacardi Limited of all of the issued and outstanding shares of Patrón.
  • International Automotive Components Group completes refinancing of Senior Secured NotesJones Day advised International Automotive Components Group, S.A., a leading global supplier of automotive components and systems, in connection with the issuance of $215 million of Senior Secured Notes due 2023 to Gamut Capital Management, L.P. in a private placement.
  • Granite Construction acquires LiquiForceJones Day advised Granite Construction Incorporated in its acquisition of LiquiForce, a privately-owned company which serves public and private sector water and wastewater customers in both Canada and the U.S.
  • Speaking Engagements

    • March 23, 2021
      Understanding and Applying Section 163(j), Tax Executives Institute Midyear Conference
    • January 14, 2021
      Cross-Border Financing: Hybrid, 163(j) Interest Limitation and Other Tax Issues, DC Bar 2021 Tax Legislative and Regulatory Update Conference
    • October 28, 2020
      GILTI and FDII Planning, 75th Annual TEI Conference.
    • October 2, 2020
      Cross-border Hybrid Issues: The Final Section 267A and 245A(e) Regulations, ABA Virtual 2020 Fall Tax Meeting.
    • August 18, 2020
      Partnership Reporting: New (Inbound) International Tax Provisions, IRS and Treasury Panel
    • June 30, 2020
      Downward Attribution under Section 958 - New Guidance and Practical Considerations, Tax Executives Institute (TEI) Midyear Conference
    • May 12, 2020
      Final and Proposed Regulations Addressing Hybrid Dividends, Hybrid Arrangements and Other Issues, DC Bar Association
    • December 19, 2019
      GILTI – Updates and Selected Issues, George Washington University-IRS Annual Institute on Current Issues in International Taxation
    • December 5, 2019
      Cryptocurrency Compliance Issues
    • December 4, 2019
      The Ethics of Emerging Technologies
    • December 3, 2019
      The Ethics of Emerging Technologies
    • October 4, 2019
      IP in the New International Tax Landscape, ABA 2019 Fall Tax Meeting
    • June 14, 2019
      The Effect of EU Information Disclosure Rules (DAC 6) and ATAD on Cross-Border Transactions with Latin America and the United States, ABA Annual U.S. and Latin America Tax Practice Trends
    • March 7, 2019
      Impact of the TCJA and BEPS on Transfer Pricing Planning, Annual Federal Bar Association Tax Law Conference
    • December 14, 2018
      Inbound developments in International Tax, George Washington University-IRS Annual Institute on Current Issues in International Taxation
    • May 11, 2018
      Inbound U.S. Tax Issues Related to Tax Reform, ABA Section of Taxation May 2018 Meeting
    • March 9, 2018
      Inbound Taxation and Tax Reform, Federal Bar Association Annual Meeting
    • March 9, 2018
      Transfer Pricing Developments, Federal Bar Association Annual Meeting
    • February 8, 2018
      The Tax Cuts and Jobs Act of 2017: How It Affects Your Business
    • February 7-8, 2018
      The Tax Cuts and Jobs Act of 2017: How It Affects Your Business
    • December 12, 2017
      International Tax Impact of Business Entity Selection for Foreign Operations of US Companies
    • October 30, 2017
      Investment Structuring and Treaty Protection
    • September 26, 2017
      Section 336(e) Elections: Tax Basis Step Up Through Deemed Asset Sale Treatment, Strafford Webinar
    • August 2, 2017
      Common Cross-border Issues in M&A and Tax Planning, ABA Webinar
    • May 11-13, 2017
      Common Cross-border Issues in M&A and Tax Planning, ABA Section of Taxation May 2017 Meeting
    • November 18, 2016
      Tax Treaty Developments, International Bar Association, The New Era of Taxation: what you need to know in a constantly changing world
    • October 25, 2016
      Recent Developments in Corporate Tax, Tax Executives Institute
    • May 7, 2016
      Fundamentals of Tax Treaties and the Competent Authority, moderator, ABA Section of Taxation May 2016 Meeting
    • May 6, 2016
      What’s New in the 2016 US Model Treaty?, ABA Section of Taxation May 2016 Meeting
    • April 27, 2016
      International Tax Seminar for Detroit Chapter of Tax Executives Institute
    • August 14, 2014
      Deal Structure in Mergers and Acquisitions (Tax-Free Reorganizations), American Management Association Course on Mergers and Acquisitions
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