John Narducci

John Narducci is a partner in the New York office and a member of the Tax Group.  Mr. Narducci’s practice focuses on the tax aspects of securities offerings, derivatives, mergers and acquisitions and financings, as well as a broad range of other transactions.

Working with issuers, underwriters and investment funds, Mr. Narducci has advised clients on numerous securities offerings, including issuances of structured notes, tender option bonds, collateralized debt obligations, credit-linked notes, contingent convertible debt instruments, prepaid forward contracts, asset-backed commercial paper and other asset-backed securities, trust-preferred securities, common stock, preferred stock, American Depositary Receipts, eurobonds, Yankee bonds, medium-term notes, high-yield debt, euro-commercial paper and interests in investment funds. Such offerings involved issuers in more than 40 countries.  His work involves the examination of tax issues with respect to such offerings, as well as the structuring of financial instruments and transactions.

Mr. Narducci has been involved in the development of tax-efficient financial structures, particularly in the cross-border context.  For example, he has created tax-efficient structures for several investment funds.  Such funds involved investments by U.S. persons abroad as well as investments in the United States by non-U.S. persons.

Mr. Narducci advises several financial institutions with respect to their derivatives transactions.  He regularly negotiates the tax aspects of ISDA Master Agreements for interest rate, currency, equity and credit default swaps and Master Repurchase Agreements, and structures various derivatives transactions.

He also has extensive experience in stock and asset acquisitions, including tax-free reorganizations.  He has represented purchasers, sellers and lenders in structuring acquisitions and negotiating the tax aspects of stock purchase and asset purchase agreements.  Many of these acquisitions involved cross-border transactions.

Mr. Narducci also works on the tax aspects of restructurings, pass-through entities, project financings and a broad range of other matters.  He has worked on the sovereign debt restructurings of Bulgaria, Costa Rica, Croatia, Nigeria, Poland and Vietnam.

Admitted in

• New York

Memberships

• American Bar Association
• New York State Bar Association: Tax Section, Committees on Financial Instruments and Foreign Activities of U.S. Taxpayers

Multimedia

Speeches & Programs

• Adjunct Professor, Fordham University School of Law, Taxation of Financial Instruments (January 2003 to June 2007)