Jamshed Patel

Jamshed J. Patel is a partner and business lawyer with Foley & Lardner LLP. Mr. Patel’s work has included principal responsibility and extensive experience in counseling clients with respect to U.S. and foreign tax matters in cross-border transactions. He is a member of the Taxation, Finance & Financial Institutions, International, and Transactional & Securities Practices.

• Transnational reorganizations and joint ventures, Section 482 transfer pricing issues, and development of tax-efficient earnings repatriation mechanisms
• Financing matters, including derivatives, hybrid securities, and other financial products
• Transfers of intellectual property to joint venture entities and to related parties; structuring cost-sharing research agreements and research funding agreements for multi-national groups; structuring intellectual property holding companies
• Regulated investment companies, private equity funds, and hedge funds

Education : Mr. Patel is a graduate of Harvard Law School and Harvard College (J.D., 1980, A.B, 1977, magna cum laude).

Professional Memberships :

Mr. Patel is a member of the State Bar of Wisconsin and the American Bar Association, and is a member of the International Tax Planning Association, a group of private tax practitioners from several countries.

Representative Matters :

• Foley served as counsel for the Wisconsin Office of the Commissioner of Insurance (OCI) in its role as domestic regulator of Ambac Assurance Corporation (AAC) and as rehabilitator of the Segregated Account of AAC.
• We have been closely involved with the overall restructuring of AAC, including the recently announced global settlement with the CDO of ABS counterparties.
• Foley advised Canadian Solar Inc., one of the world’s largest solar power companies, in its acquisition of Recurrent Energy, LLC, a leading North American solar energy developer, from Sharp Corporation for approximately $265 million.
• This represents the largest solar transaction to date that the Foley Energy Industry Team has closed.
• Foley represented Brite Energy in financing a $200 million Morgan Stanley tax equity fund in residential solar projects in multiple states across the U.S. This investment program in conjunction with MySolar IX, will assist in affordable and clean energy.
• Foley represented Brite Energy in financing a $200 million Morgan Stanley tax equity fund in residential solar projects in multiple states across the U.S. This investment program in conjunction with MySolar IX, will assist in affordable and clean energy.
• Represented a global developer in the structuring and negotiating of a joint venture to co-develop, own and operate 28 solar and wind projects with estimated nameplate capacity in excess of 1,000 MWs in Japan under the Japanese FIT program, which included the structuring of a G.K. (godo kaisha) joint venture entity.
• Served as bond counsel for this first-of-its-kind bond issue, involving general obligation guaranty to support revenue bonds issued to purchase rehabilitated defaulted student loans from the loan guarantor.
• Since 2007, represented one of the nation’s largest public pension funds in negotiating and renegotiating its swaps and derivatives master agreements with its trading partners.