Find Lawyers

Jeff Paravano is Managing Partner of BakerHostetler’s Washington, D.C., office. He previously served as firmwide Chair of the firm’s Tax Group, which is among the largest law firm tax practices in the United States. Before returning to the firm from Treasury in 2003, Mr. Paravano served as Senior Advisor to the Assistant Secretary, Tax Policy, at the United States Department of Treasury. While at Treasury, Mr. Paravano was responsible for providing advice on a wide range of tax policy and technical issues, including tax legislation and corporate, partnership, REIT, and financial sector tax guidance. He also was one of the primary authors of the final tax shelter regulations and is author of the Tax Management Portfolio on Tax Shelters, T.M. 798.

Mr. Paravano has a broad-based tax practice involving tax litigation; corporate, partnership and venture capital transactions; and domestic and cross-border tax planning. He also represents clients’ interests before federal policy makers, enforcement officials, and on Capitol Hill.

Mr. Paravano has assumed numerous positions of service in academia and to the legal profession. He is a Fellow of the American College of Tax Counsel and a member of the American Bar Association, Section of Taxation, where he has served in various capacities, including as Chair of the Affiliated and Related Committee and Chair of the Committee on Government Submissions. He has been an adjunct professor in the LL.M. tax programs at Georgetown University Law Center and Case Western Reserve University School of Law and has served on the Editorial Advisory Boards of various tax publications. Mr. Paravano has written and lectured extensively on tax topics and has chaired numerous tax programs, panels and task forces. He routinely is among those named in Chambers USA, Who’s Who Legal, Best Lawyers in America and Super Lawyers, is a past president of the Tax Club and was Editor in Chief of The Tax Lawyer.

Mr. Paravano’s practice includes a significant amount of large-case controversy work involving both domestic and international tax issues. He has represented clients under audit, at IRS Appeals, and in Tax Court, refund and appellate litigation. He was a member of the team that represented a multinational oil company in the United States Tax Court where more than $1.3 billion in tax and interest was at stake with respect to a Section 482 transfer pricing issue alone. At the audit stage, Mr. Paravano has assisted clients facing several hundred significant issues affecting numerous related corporations located in taxing jurisdictions around the globe. He advises with respect to the merits of particular items and the interrelation of domestic and international tax issues.

Mr. Paravano has assisted clients with, among other matters, shortening the examination process by focusing attention on significant issues and resolving issues not warranting litigation, evaluating which adjustments made by teams of IRS agents should be protested to IRS Appeals, preparing written protests and administrative settlement agreements, obtaining abatement of various types of penalties, obtaining private letter rulings, closing agreements and other forms of IRS National Office and Field advice, selecting and preparing witnesses and reputable and effective experts, providing advice in disputes over IRS demands for documents and information, including challenges to and defenses against administrative summonses, arguing against the validity of regulations, considering the appropriateness of filing amicus briefs, and selecting and litigating various test cases. Mr. Paravano is part of the BakerHostetler team that serves as court-appointed Counsel to the SIPA Trustee for the liquidation of Bernard L. Madoff Investment Securities LLC (BLMIS), working on the $326 million settlement with the IRS in which it was determined that BLMIS falsely debited the accounts of 145 foreign account holders for alleged U.S. federal income tax withholding and paid to the IRS such withheld amounts related to alleged dividends.

Mr. Paravano’s transactional tax practice includes assisting clients with structuring, negotiating, and documenting corporate, partnership, and limited liability company formation, merger, acquisition, disposition (including spin-off transactions, asset sales, stock sales, and Section 338(h)(10) transactions), joint venture, and financing transactions—working closely with clients, investment bankers, and the IRS National Office, as necessary, and adhering to aggressive timetables in order to maximize client business opportunities.

Mr. Paravano also provides independent advice to tax directors and board committees with respect to tax minimization strategies proposed by others or developed in-house. He has assisted multinational corporations with shelter regulation compliance, provided advice to professional service organizations regarding promoter audits, advised a national accounting firm regarding strengths and risks associated with certain tax minimization strategies, advised a global investment banking firm and other clients in connection with the development of procedures and internal controls with respect to tax minimization strategies and transactions affecting book income, and, while at Treasury, worked with IRS officials regarding the development of the first three global settlement initiatives for Listed Transactions.

Mr. Paravano’s international tax practice has included assisting clients with multifaceted international matters, including structuring inbound and outbound business and real estate investments; cross-border mergers, dispositions, and joint ventures; reorganizing and restructuring multinational corporate groups; creating centralized cash management centers; handling international controversies before the IRS and in the courts; and devising specialized planning involving transfer pricing, foreign entity classification, foreign tax credits, foreign currency transactions, profit repatriations, and tax treaty issues.

Mr. Paravano has advised a number of publicly traded real estate investment trusts (“REITs”) and a number of private REITs on an ongoing basis with respect to various issues, including going public, secondary offerings of debt and equity (including use of private REIT structures to raise nearly $1 billion of capital from non-U.S. equity markets), tax compliance and private letter ruling requests, mergers with public REITs, private REITs and non-REITs, UPREIT structures, DownREIT transactions, and structuring and negotiating joint ventures and limited liability company agreements with developers, pension funds, venture capital funds, and other non-REITs. He has acted as tax counsel to the Special Committee of the Board of Directors of another publicly traded REIT charged with evaluating merger, management buy-out, and other bids in connection with the auction of the REIT, and as Special Tax Counsel for a number of REITs seeking closing agreements from the IRS regarding REIT qualification issues. Mr. Paravano has worked extensively with NAREIT and the Real Estate Round Table with respect to legislative and tax policy issues.

Mr. Paravano has assisted clients experiencing financial difficulties with developing realistic plans and alternative proposals for restructuring debt and equity, and has advised lender and borrower clients in connection with workouts and other capital restructurings.

Mr. Paravano’s writings related to taxation include, among others, “Tax Shelters,” Tax Management Portfolio, T.M. 798; "Revised Bailout Plan with New Tax Provisions Passes Congress," Derivatives Financial Products Report, Vol. 10, No. 3 (November 2008) (co-author); “The New Circular 230 Regulations—Best Practices or Scarlet Letter?” BNA Tax Management Memorandum (August 22, 2005) (co-author); “Tax Shelters: Evaluating Recent Developments,” Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings, Practising Law Institute (annually 2000-2012) (co-author); “A Taxing Idea,” The Washington Times (October 26, 2004) (co-author); “Planning Transactions After Installment Method Repeal,” 1 Corporate Business Taxation Monthly No. 12 (September 2000) (co-author); “Evaluating Recent Tax Shelter Guidance,” 1 Corporate Business Taxation Monthly No. 9 (June 2000); “Business Purpose After ACM and Tax Shelter Reform,” 1 Corporate Business Taxation Monthly No. 1 (October 1999) (co-author); Annual Important Developments, Corporate Tax, The Tax Lawyer, Vols. 49-53 (1996-2000) (contributor); “Section 482: Its Application to Partnership Transactions from Organization to Liquidation,” Journal of Partnership Taxation (Spring 1996) (co-author); “Litigation of Partnership Items,” published as Chapter 9 of treatise, Litigation of Federal Tax Controversies; “IRS Adopts ‘Capacity’ Approach for Treatment of Receipt of Partnership Profits Interest,” 62 Tax Notes 89 (January 3, 1994); “New Notice Establishes Procedures for Coordinated Team Approach in Large Cases,” 60 Tax Notes 515 (July 26, 1993) (co-author); assisted primary author David C. Garlock with revision of treatise: Federal Income Taxation of Debt Instruments (1992-93); “Receipt of a Partnership Profits Interest in Consideration for Services Rendered—Life After Campbell,” 44 Tax Lawyer 529 (1991); and Note, “Postpetition Interest on Oversecured Tax Liens—Abandonment of the ‘Nonconsensual’ Distinction in Bankruptcy Proceedings: United States v. Ron Pair Enterprises,” 42 Tax Lawyer 475 (1990).

Mr. Paravano has represented various community and charitable organizations on a pro bono basis and advises non-filers and persons owning interests in off-shore accounts with respect to IRS amnesty regarding criminal charges, waiver of penalties for reasonable cause, and other matters. He has been a member of John Carroll University’s Board of Regents and a member of the Board of Directors of the Tannenwald Foundation for Excellence in Tax Scholarship.