LoriHellkamp

Partner

Washington + 1.202.879.3787

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Lori Hellkamp provides creative solutions to complex tax issues by taking a 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 structuring for cross-border transactions and investments. Lori has extensive experience helping clients address issues arising from foreign (inbound) investments into the United States and in the fintech sector. She also regularly advises clients on tax and structuring issues related to cryptocurrencies and other digital assets.

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, withholding, FIRPTA (Foreign Investment in Real Property Tax Act), anti-boycott, and international tax reform issues.

Lori is a board member of the George Washington University-IRS International Annual Tax Institute, an adjunct professor of international taxation at American University, and the former chair of the ABA Tax Section's Committee on U.S. Activities of Foreigners & Tax Treaties (USAFTT). She frequently speaks and publishes articles on various international and corporate tax topics. Lori also is a member of the ABA's task force on cryptocurrency, a coauthor of the book Blockchain for Business Lawyers, and the hiring partner for the Washington Office of Jones Day.

Experience

  • NerdWallet acquires On The Barrelhead for $120 millionJones Day advised NerdWallet, Inc. (Nasdaq: NRDS), a platform that provides financial guidance to consumers and small- and mid-sized businesses, in its acquisition of On the Barrelhead, Inc. for total consideration of $120 million, consisting of approximately $70 million in cash and $50 million in NerdWallet Class A common stock.
  • Simpson Manufacturing Company announces offer to acquire Etanco GroupJones Day advised Simpson Manufacturing Company, Inc. in the €725 million acquisition of the Etanco Group.
  • MassMutual partners with Low Carbon to accelerate transition to renewable energyJones Day advised Massachusetts Mutual Life Insurance Company (MassMutual) on its debt and equity investment in Low Carbon Energy Holdings Limited (“Low Carbon”), a subsidiary of Low Carbon Limited, an established pan-European renewable energy developer and fund manager.
  • Raine Capital invests in Mythical GamesJones Day advised Raine Capital LLC in its Series C Preferred Stock investment in Mythical Games, including advice regarding tokenized digital assets of Mythical Games.
  • Misonix merges with BioventusJones Day represented Misonix, Inc. (Nasdaq: MSON) in its acquisition by Bioventus Inc. (Nasdaq: BVS).
  • Bridge to Life announces first close of $56 million growth financingJones Day advised Bridge to Life, Ltd. in its $56 million capital raise consisting of a secured credit facility and a Series A preferred equity investment.
  • Huntington Ingalls Industries acquires Alion Science and Technology for $1.65 billionJones Day advised Huntington Ingalls Industries in the $1.65 billion acquisition of Alion Science and Technology Corporation from Veritas Capital.
  • DraftKings launches sports-memorabilia NFT marketplace in U.S.Jones Day is advising DraftKings Inc. on regulatory and legal matters related to the launch of a sports-memorabilia NFT marketplace in the United States.
  • Skyworks Solutions acquires Infrastructure and Automotive business of Silicon Laboratories for $2.75 billionJones Day advised Skyworks Solutions, Inc., an innovator of high-performance analog semiconductors, in connection with its acquisition of 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.
  • OEConnection acquires SmartCo Services LLCJones Day advised OEConnection LLC in its acquisition of SmartCo Services LLC, a web-based technology company.
  • 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.
  • 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.
  • Huntington Ingalls sells San Diego Shipyard to Titan Acquisition HoldingsJones Day advised Huntington Ingalls Industries in the sale of its San Diego Shipyard to Titan Acquisition Holdings.
  • 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.
    • View All

    July 2024 Alert

    Supreme Court Upholds the Mandatory Repatriation Tax in Moore v. United States

    SEPTEMBER 2023 Alert

    Much-Anticipated Tax Reporting Regulations on Digital Asset Transactions Issued

    July 2023 Alert

    IRS Updates Fast-Track Program for Certain Corporate Tax Rulings

    October 2022 White Paper

    Digital Assets Defined: The Tax Code's Take

    August 2022 Commentary

    Inflation Reduction Act Imposes New Tax on Corporate Stock Repurchases

    August 2022 Video

    JONES DAY PRESENTS®: Tax Implications of Telehealth as Remote Services Become the Norm

    July 2022 White Paper

    Digital Assets Defined: How Lummis-Gillibrand Will Shape the Coming Fintech Debate

    March 2022 Alert

    White House Issues Executive Order Calling for Inter-Agency Study of Digital Assets

    March 2022 Commentary

    California Unclaimed Property Amnesty on the Horizon

    January 2022 Alert

    New Fast-Track IRS Guidance for Spin-Offs and Other Corporate Transactions
    View All

    Additional Publications

    • August 2021
      Demystifying the Saving Clause and Re-Sourcing Rules in Treaties, Tax Notes and Tax Notes International
    • June 2020
      It's Time to Look Again at the Anti-Hybrid Rules, Tax Notes Federal and Tax Notes International
    • July 5, 2019
      Virtual Money (or Property), With Real-World Tax Implications, Corporate Counsel Business Journal
    • February 2019
      Brexit and NAFTA Demise Could Jeopardize U.S. Treaty Benefits, Tax Notes International

    January 25 and 26, 2023 Speaking Engagements

    2023 D.C. Bar Tax Legislative and Regulatory Conference

    Additional Speaking Engagements

    • December 12, 2024
      Tax Treaty Issues and Implications for Cross-Border Trade and Investment, 35th Annual GW-IRS Institute on International Taxation
    • November 18, 2024
      Controlled Foreign Corporation Planning, NYU 83rd Annual Institute on Federal Taxation
    • April 11, 2024
      Inbound Investments in the US, European & US Tax Practice Trends Annual IFA/ABA Conference
    • November 14, 2023
      Troubled Companies: Pitfalls and Opportunities, NYU Institute of Federal Taxation
    • November 13, 2023
      International M&A: US Tax Considerations and Planning, NYU Institute of Federal Taxation
    • June 14, 2023
      Blockchain, Cryptocurrency and the New Frontier, ABA Annual US & Latin America Tax Practice Trends Conference
    • March 30, 2023
      The Role of Competent Authority and Double Taxation Resulting from DSTs, Minimum and Other Taxes, US and Europe Tax Practice Trends Annual ABA Conference
    • February 10, 2023
      International Information Exchange for Tax Controversy, 2023 ABA Midyear Tax Meeting
    • January 25 2023
      Taxation of Cryptocurrency and Related Reporting Issues, DC Bar Annual Tax Legislative and Regulatory Update Conference
    • December 21, 2022
      US Tax Treaties - What You Need to Know, Lorman Webinar
    • December 15, 2022
      Foreign Tax Credit Developments, GWU-IRS Annual Institute on Current Issues in International Taxation
    • November 14, 2022
      International Mergers & Acquisitions: U.S. Tax Considerations & Planning Techniques, 81st NYU Institute on Federal Taxation
    • October 25, 2022
      Tax Considerations in FinTech, FinAccelerate
    • May 13-14, 2022
      The Good, the Bad, the GILTI – OECD Pillar 2 & the U.S. GILTI Regime, 2022 Annual ABA Tax May Meeting
    • May 4, 2022
      International Tax: Inbound Developments, DC Bar Annual Tax Legislative and Regulatory Update Conference
    • April 13, 2022
      U.S. Income Tax Treaties and Claiming Treaty-Based Positions, Lorman Webinar
    • April 1, 2022
      Where Did I Park My IP? Rewriting the ABCs of Taxation of Intellectual Property, ABA Annual Conference on US & Europe Tax Practice Trends
    • December 8, 2021
      Pharma Tax Considerations in Strategic M&A, Joint Ventures, Co-development and Royalty Sales
    • October 19, 2021
      Taxes and Cryptocurrency, Lorman Webinar
    • June 18, 2021
      The Biden Administration's Tax Reform: Potential Impact on Australian Investment in the United States
    • 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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