Biography
Ronald D. Kerridge is a seasoned and practical federal income tax lawyer. Ron divides his time between transactional tax matters and tax controversies.
On the transactional side, Ron’s practice emphasizes tax structuring of acquisitions and strategic partnerships. He has advised both publicly traded and privately held clients on taxable and tax-free acquisitions. Ron also assists clients with issues involving S corporations, limited liability companies, and partnerships. He has significant experience in real estate matters, including REITs and 1031 exchanges. Ron also advises concerning in-bound and out-bound international tax structuring, oil and gas tax issues, and the tax considerations present in settling commercial and employment litigation.
In his controversy practice, Ron represents clients before the IRS on a wide variety of federal income tax issues. These issues have included life insurance company reserves, abandonment losses, sales of transferable tax credits, reasonable compensation, “hobby” losses, passive activity losses, S corporation “built-in gains” tax, oil and gas carries, accumulated earnings tax, and imposition of tax penalties, including responsible-person and shelter-promoter penalties. He has also handled controversies involving “listed transactions,” including Notice 2001-16, intermediary transactions. Ron has acted as an arbitrator in a dispute between two publicly traded companies concerning a tax sharing agreement in connection with a spin-off.
Ron’s experience in handling tax controversies makes him a very practically-minded transactional tax lawyer.
Education
A.B., summa cum laude, Princeton University
- Phi Beta Kappa
J.D., magna cum laude, Harvard Law School
Bar Admissions
Texas, 1987
Court Admissions
United States Supreme Court
United States Court of Federal Claims
United States Tax Court
- Ron has represented numerous buyers and sellers of businesses in connection with the tax aspects of such transactions, including acquisitions and strategic joint ventures with aggregate value of more than $6 billion.
- Ron convinced the Appeals Division of IRS to concede entirely a proposed deficiency in excess of $50 million arising from a sale transaction, preserving the nest eggs of the two retired founders of a private company.
- Ron obtained complete concessions from the IRS in three matters involving asserted liability in excess of $10 million each.
- Represented a registered investment advisory firm focused on utility and infrastructure-related investments in connection with its signing of a deal to invest $675 million in common stock of PG&E Corporation in a private placement of public equity (PIPE) transaction which, together with other investors, was part of a $3.25 billion investment expected to close upon PG&E emerging out of bankruptcy.
- Ron has advised a client on the tax aspects of a strategic joint venture that will create the largest wine and spirits distributor in the U.S.
- Ron represented a leading provider of B2B digital transformation services in the sale of its business to a Dallas-based private equity firm for an undisclosed amount.
- Ron represented the nation’s largest mobile contract grinding and recycling service in the acquisition of a Fort Worth-based provider of mobile contract grinding, delivery, and green waste recycling services.
- Ron has developed innovative approaches for sharing earn-outs in a sale transaction with ongoing members of company management.
- Ron represents clients in federal legislative and regulatory matters.
- Ron obtained complete concessions or favorable settlements from the IRS in numerous other matters.
- Ron obtains private letter rulings from the IRS.
- Ron helps with planning to restructure businesses to minimize Texas tax liability.
- Ron served as Chair of the Dallas Bar Tax Section in 2011.
- “Texas Super Lawyer,” Super Lawyers by Thomson Reuters, 2007-2019
- The Best Lawyers in America (Woodward/White Inc.)
- Tax Law, 2007-2020
- Litigation & Controversy – Tax, 2012-2020
- “Best Lawyers in Dallas,” D Magazine, 2013-2020
- Texas Bar Foundation, Fellow
- American Law Institute
- Texas Bar Foundation, Fellow
- State Bar of Texas – Tax Section
- Dallas Bar Association – Tax Section, Past Chair