White & Case

Sang I. Ji
Partner, New York
Contact Info
Sang I. Ji
Partner
1155 Avenue of the Americas
New York, New York
10036-2787
United States
T: + 1 212 819 8805
F: + 1 212 354 8113

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Practice Experience
Mr. Ji is engaged in a domestic and international tax practice with an emphasis on tax issues arising in mergers and acquisitions, securities offerings, financial products, investment funds, and controversies with the U.S. Internal Revenue Service.

He has extensive experience in stock and asset acquisitions, including tax-free reorganizations.  Many of these transactions were cross-border deals that required complex structuring to accommodate the business and tax considerations of the parties involved.

Mr. Ji has worked extensively with issuers and underwriters around the world on a broad array of securities offerings, including income deposit securities, convertible redeemable preferred stock, structured notes, and complex trust instruments.  Many of these offerings have required the creation of tax-efficient structures that navigate the varied requirements of multiple taxing jurisdictions.

He also advises investment funds and investors in such funds on tax-efficient structures for investments by United States persons outside the United States, as well as investments in the United States by non-United States persons.

Mr. Ji's recent representations include U.S. tax advice in connection with:
  • The reorganization of the global Visa payments network into a single global public company, including tax disclosure for documents filed with the U.S. Securities and Exchange Commission relating to Visa’s initial public offering and pre-IPO restructuring;
  • The issuance and guarantee by Canada Housing Trust and Canada Mortgage and Housing Corporation, respectively, of over $70 billion in Canada Mortgage Bonds;
  • The $36.5 billion sale of Burlington Resources, Inc., one of the world’s largest independent oil and gas exploration and production companies at the time, to ConocoPhillips in a transaction structured as a tax-free reorganization;
  • The public offerings of over C$400 million in income deposit securities by New Flyer Industries Inc. and New Flyer Industries Canada ULC, the leading manufacturer of heavy-duty transit buses in the United States and Canada; and
  • The examination by the U.S. Internal Revenue Service of Arthur Andersen LLP's promotion of tax-structured products.

Mr. Ji advises on a wide array of tax issues, including those related to partnerships, consolidated groups, net operating losses, controlled foreign corporations, passive foreign investment companies, FIRPTA, corporate inversions, and treaty benefits.  He also works on the tax aspects of restructurings, joint ventures, project financings and a broad range of other matters.  His work spans various industries, including energy, financial services, insurance, and technology.

Prior to joining White & Case LLP, Mr. Ji served as an attorney-adviser to Judge James S. Halpern of the United States Tax Court.

Bars and Courts
New York State Bar, 1997
New Jersey State Bar, 1996
US District Court for the District of New Jersey

Education
LLM, Taxation, New York University School of Law, 2002
JD, Columbia Law School, Harlan Fiske Stone Scholar, 1996
BA, Columbia College of Columbia University, Dean's List, 1993

Professional Associations and Memberships
New York State Bar Association

Publications
Letter to the Editor, "The Material Adviser Rules in the New Tax Law Are Too Broad," 105 Tax Notes 757, Nov. 1, 2004
Co-author, "Recent Amendments to the Tax Court's Rules of Practice and Procedure:  A Response to the Court's Expanded Jurisdiction," 1 J. Tax Prac. & Proc. 32, Aug./Sept. 1999
Author, "Nonrecourse Financing of Real Property:  Depreciation Allocation and Full Recapture to Minimize Deferral and Eliminate Conversion," 29 Colum. J.L. & Soc. Probs. 217, 1996

Languages
English
Korean

Citizenship
United States



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