Sang I. Ji
Sang Ji's practice focuses on domestic and international tax law. He has particular experience with tax issues arising from mergers and acquisitions, securities offerings, financial products, investment funds and controversies with the US Internal Revenue Service.
Sang's experience extends to stock and asset acquisitions, including tax-free reorganizations. Many of these transactions are cross-border deals that required complex structuring to accommodate the business and tax considerations of the parties involved.
Further tax issues on which Sang is able to help clients include 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.
Sang works 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.
Clients from a range of industries including energy, financial services, insurance and technology come to Sang for his tax expertise. Notable recent transactions on which he has advised include the acquisition of Pinebridge Investments, the reorganization of the global Visa payments network, arranging the issuance and guarantee of CDN$236 billion in Canada Mortgage Bonds, and the US$36.5 billion sale of Burlington Resources, Inc.
Prior to joining White & Case LLP, Sang served as an attorney-adviser to Judge James S. Halpern of the United States Tax Court.
Harvest Partners, 2014
Sang represented Harvest Partners in the Athletico transaction, which involved the acquisition of a network of physical therapy businesses valued at approximately US$400 million. Prior to an internal reorganization undertaken in connection with the transaction, the business was legally structured as approximately 70 legal entities, separately owned by the founding physical therapist and a physical therapist manager.
Quad-C: Cloverhill Holdings, LLC, 2014
Sang represented Cloverhill Holdings, LLC, the portfolio company of our long-time client Quad-C Management, Inc., and the indirect parent of Cloverhill Bakery, in its US$700 million sale to the Swiss-based food group Aryzta AG.
CDN$236 billion in Canada Mortgage Bonds, ongoing
Sang arranged the issuance and guarantee of over CDN$236 billion in Canada Mortgage Bonds for Canada Housing Trust and Canada Mortgage and Housing Corporation.
Quad-C: Interwrap, 2013
Sang represented Quad-C Management, Inc. in its acquisition of a 50 percent interest in the InterWrap Group, a global manufacturer of innovative coated woven products and diverse multi-layer laminated reinforced plastic substrates.
Credit Suisse's US$450 million senior secured credit facility, 2012
Sang advised Credit Suisse, as sole lead arranger and administrative agent, in connection with the US$450 million senior secured credit facility provided to Lord & Taylor Holdings LLC. His advice was sought on matters relating to tax, since proceeds from the term loans were used to partially refinance outstanding commercial mortgage-backed securities and to pay related fees and expenses. Lord & Taylor is owned by NRDC Equity Partners LLC.
The Material Adviser Rules in the New Tax Law Are Too Broad, 105 Tax Notes 757, November 2004, Letter to the Editor
Leading Lawyer for Tax in the United States, Euromoney's Expert Guide, 2018
Tax Directors Handbook 2012
US: International Tax
The Legal 500 USA 2011
US: International Tax