Stephen Jackson, partner in Orrick's Paris office, is a member of the Tax group.

Mr. Jackson's practice covers a wide range of U.S. federal income tax matters arising in connection with various domestic and international transactions, as well as financial products and tax planning for financial institutions. His primary focus is on U.S. taxation of securitizations and re-securitizations, including collateralized debt and loan obligations, mortgage-backed securitizations, structured investment vehicles and other structured finance and financial markets transactions.

For over a decade, Mr. Jackson has served as tax counsel to issuers and underwriters in numerous registered, agency and privately-placed RMBS transactions (primary issuances and re-securitizations), involving performing loans and non-performing loans, as well as other mortgage-related asset classes, such as servicing advances and tax liens, and in securitizations involving other asset classes such as credit card and auto
loan/lease receivables. Mr. Jackson also provides tax advice in connection with whole loan purchase transactions, including leveraged and nonleveraged acquisitions, joint ventures involving mortgage assets and repo and warehouse financings for various asset classes. Mr. Jackson also advises financial institutions on tax issues in connection with their role as
servicer, trustee or securities administrator under various securitization programs, as well as with respect to FATCA.

Mr. Jackson writes and lectures on finance and international related tax topics and also participates actively in the tax committee and other initiatives of the Structured Finance Industry Group and other industry and bar-related organizations.

Stephen Jackson
Select Publications
  • IRS Issues Final Regulations and New Proposed Regulations Regarding Withholding on Derivatives on U.S. Stocks (12-30-2013)
  • IRS Issues Changes to the Mixed Straddle Account Regulations (8-21-2013)
  • Treasury and IRS Extend FATCA Deadlines (7-19-2013)
  • Final Regulations Implementing the Foreign Account Tax Compliance Act ("FATCA") (3-29-2013)
  • House Ways and Means Proposals for Financial Products Tax Reform (2-24-2013)
  • IRS Amends Temporary Treasury Regulations under Section 871(m) (9-14-2012)
  • IRS Issues Guidance on Outbound Transfers of Intangible Property in Asset Reorganizations (8-27-2012)
  • Additional Guidance on the FATCA Reporting and Withholding Regime (6-24-2011)
  • The Economic Substance Requirement -- A Multi-Jurisdictional Perspective (The Euromoney Corporate Tax Handbook (2011))
  • IRS Issues Final Treasury Regulations Expanding Definition of "Traded on an Established Securities Market" and Liberalizing Rules for Reopenings (9-28-2010)
  • New Permitted Loan Modifications and Revised Lien Release Rule for REMICs (9-18-2009)
  • Lending, An Overview (PLC US Special Report (2009))
  • The Taxation of Derivatives - Recent Changes, Future Directions - London Financial Markets Breakfast Briefing (4-17-2008)
  • Selected International Provisions of the American Jobs Creation Act of 2004 Affecting Canadians Doing Business in the U.S. (Corporate Finance (Winter 2005))
  • Selected International Provisions of the American Jobs Creation Act of 2004 (December 2004)
  • Securitization Related Provisions of the American Jobs Creation Act of 2004 (10-25-2004)
Languages
  • English
  • French
Admitted In
  • California
  • New York
  • England and Wales
  • Paris

Education
  • J.D., with distinction, Stanford Law School, 1996
  • B.S., summa cum laude, Mechanical Engineering, University of Missouri - Kansas City, 1993
Memberships
  • New York State Bar Association
  • American Bar Association
  • Structured Finance Industry Group

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