Jamie K. Ogden

Jamie Ogden advises U.S. and non-U.S. individuals and families on sophisticated income, estate and gift tax planning, as well as business succession and general family office matters.

In that context, Jamie advises clients on all aspects of tax law with a particular focus on federal and state income tax issues related to complex mergers and acquisitions, business formations, divestitures, joint ventures, real estate, partnership and S-Corporation transactions, QSBS planning, residency and family office matters. He also works frequently with his Private Client colleagues with respect to gift/estate tax planning, in addition to litigators on the tax aspects of settlements and judgments.

Jamie represents a diverse roster of individual and entity clients, including strategic and corporate buyers and sellers, family offices and high net worth individuals and litigants. His work spans a wide range of industries, such as law firms and accountings firms, fund formations, hospitality and real estate, manufacturing and construction, information technology, software and intellectual property, retail, media and entertainment—including many significant catalogue sales—in addition to start-ups in a myriad of other industries.

Working closely with the firm’s Corporate and Private Client practices, Jamie guides clients through every stage of complex transactions—from pre-LOI negotiations and pre-close structuring (including Type F transactions and PTE planning) to post-closing integration, in conjunction with estate tax and multi-state income tax planning. He has extensive experience negotiating with opposing counsel on critical tax issues within the context of complex transactions and preparing and drafting key transactional documents, including merger, stock purchase, asset purchase and membership interest purchase agreements, as well as partnership and LLC operating agreements, S-corporation arrangements and private letter rulings.

Jamie also handles high-stakes controversy matters before both the Internal Revenue Service (IRS) and the California Franchise Tax Board. He also has deep experience advising on foreign compliance matters (such as FBARs and other annual disclosure forms), including all variations of IRS amnesty programs.