William Hornberger is passionate about the practice of law and about helping people and enterprises achieve business goals. He is extremely grateful to his mentors, Larry Bean and Vester Hughes, because they not only taught him to be passionate about the law, they also modeled for him character and class and taught him how to have a rich and fulfilling life outside of the office. For nearly 30 years, he has practiced in the areas of tax, transactional, international and corporate law at Jackson Walker and has loved every minute of it! His tax practice has touched nearly every area of the tax law, including corporate, partnerships and LLCs, international, real estate, corporate, oil and gas, bankruptcy, tax credit and tax controversy and procedural matters. His broad transactional practice includes mergers and acquisitions, complex partnership, joint venture, real estate and private equity arrangements, complicated cross-border business structuring matters involving investors from multiple countries, Tax Treaty and IRS Competent Authority matters. He has represented taxpayers on tax controversy matters in IRS administrative appeals and before the U.S. Tax Court, the U.S. District Court, the U.S. Bankruptcy Court, the Courts of Appeals for the Fifth and Eleventh Circuits and the U.S. Court of International Trade.
Tax and Transactional
- Structuring taxable and nontaxable acquisitions, including public-traded corporations, partnerships, limited liability companies, S corporations and REITs and tax-exempt entities.
- Structuring the formation and operation of private equity funds.
- Structuring all types of tax-free corporate acquisitive and divisive reorganizations, including mergers, stock-for-stock transactions, assets-for-stock transactions, and recapitalizations.
- Drafting of complex limited partnership agreements.
- Structuring Carried Interest Transactions.
- Structuring acquisitive and divisive transactions involving partnerships and limited liability companies.
- Structuring partner buyouts.
- State tax planning.
- Structuring equity-based compensation arrangements.
- Structuring derivative transactions (including cross-border transactions).
- Tax planning for intellectual property.
- Taxation of modification of debt instruments.
- Private letter ruling requests.
- Tax planning for installment sales.
- Structuring real estate partnerships involving entities of all types, including corporations, partnerships, limited liability companies, S corporations, non-U.S. investors, REITs and tax-exempt entities.
- Structuring the formation of REITs;
- Privatization of REITs.
- Structuring of cross-border REITs.
- Structuring like-kind exchanges (real and personal property).
- Structuring tenancy-in-common and co-ownership arrangements.
- Tax aspects of workouts, including foreclosures.
- Planning for debt-financed distributions from partnerships and limited liability companies.
- Extensive experiences with tax controversies in the U.S. Bankruptcy Court, including cases involving concurrent jurisdiction with the U.S. Tax Court.
- Planning for utilization of net operating losses.
- Extensive experience in handling administrative tax controversies with the IRS and domestic and international tax controversies in the following U.S. courts: U.S. Tax Court, U.S. District Court, U.S. Federal Courts of Appeal, and U.S. Court of Federal Claims; U.S. Bankruptcy Court.
- Extensive experience with the IRS Offshore Voluntary Disclosure Program.
- Structuring oil and gas limited partnerships.
- Structuring energy-related acquisitions, including oil and gas interests ( all types) and pipeline.
- Structuring international oil and gas operations.
- Structuring oil and gas private equity funds.
- Production Payment transactions.
- Tax planning for intangible drilling costs.
- Like-kind exchanges of oil and gas properties.
- Formation, operation and taxation of tax-exempt entities.
- Joint Ventures involving tax-exempt entities.
- Domestic and cross-border acquisitions and dispositions of U.S. and non-U.S. entities.
- Structuring of tax-free domestic and international reorganizations.
- Extensive experience with anti-inversion rules.
- Structuring litigation settlements.
- Cross-border derivative trading – structuring and taxation.
- Structuring international operations for U.S. multinationals.
- Utilizing holding companies in international tax planning.
- Corporate, LLC and partnership transactions involving non-U.S. persons investing in U.S. real estate.
- Legal interpretation and analysis of tax treaty issues.
- Foreign tax credit utilization.
- Structuring of cross-border investments in private equity funds.
- Taxation of currency gains and losses.
- Structuring inbound capitalization structures, including planning involving utilization of the portfolio interest exemption.
- Transfer pricing issues and studies involving sales, services and intangibles, including working with economists.
- Structuring of cross-border trucking operations.
- Taxation of nonresident workers present in the U.S. and taxation of U.S. employees outside the U.S.
- Extensive experience with FATCA limitations.
- American Bar Association, Member, 1988-Present
- State Bar of Texas, Chair of Section of Taxation, 2001-02
- Dallas Bar Association, Chair of Section of Taxation, 2005
- Texas Bar Foundation, Life Fellow
- American Institute of CPAs, Council Member, 2014-17
- American Institute of CPAs, Nominating Committee, 2016-18
- Texas Society of CPAs, Chair, 2013-14
- Texas Society of CPAs, Executive Board, 2009-15
- Dallas CPA Society, Chair, 2008-09
- Dallas CPA Society, Board of Directors, 2009-present
- Dallas Holocaust Museum, Treasurer and Executive Committee Member, 2010-11; Board Member, 2008-16; Advisory Board, 2005-08
- Real Estate Council of Dallas, Executive Committee, 2008 and 2011; Chair, 2011 Fall Gala
- Real Estate Council Foundation, Board of Directors, 2006-08
- AVANCE Dallas, Inc., Board Chair, 2014-present; Board Vice-Chair 2012-14
- The Covenant School, Board Member, 2003-09
- Leadership Dallas, 2006
- Dallas Assembly, Member, 2011-present
- Prospanica (formerly National Society of Hispanic MBAs), National Corporate Counsel, 2010-present
- General Counsel/Development Phase, Klyde Warren Park, 2008-12
- Counsel for Commemorative Air Force, 2016-present
- Ozone Dallas, Board Member, 2012-13
- Dallas Latino Street Fest, Founding Chair, 2014-18
- SMU School of Law, Adjunct Professor in Taxation, 1996, 1998
News & Events
- News & Publications
Best Lawyers in America Recognizes 98 Jackson Walker Attorneys
‘D Magazine’ Lists 33 Jackson Walker Attorneys Among Best Lawyers in Dallas
Willie Hornberger Speaks at SelectUSA Investment Summit
Port Aransas Boatmen Selects Willie Hornberger as Outside General Counsel and Jackson Walker as Tournament Sponsor for the 83rd Annual Deep Sea Roundup
Jackson Walker’s Online Interactive Analysis of the Tax Reform Law is Available Now
53 Jackson Walker Attorneys Named to 2017 ‘Texas Super Lawyers’ List
Jackson Walker Attorneys Speak on US-Mexico Relations at CPA Conference in Mexico
Best Lawyers in America Recognizes 94 Jackson Walker Attorneys
D Magazine Recognizes Eleven Jackson Walker Attorneys
Jackson Walker Congratulates its 54 Attorneys Added to ‘2016 Texas Super Lawyers’ List
William Hornberger, Wayne Malecha, and David Moran Included in ‘Dallas 500’ List
Velocis Fund I Ranked in Preqin’s Top 10 Best Performing Core Private Real Estate Funds
Jackson Walker Congratulates Its Best Lawyers in America 2016
William Hornberger, Cale McDowell, Steve Moore and Tom Groves Speak at Texas Society of CPAs’ 2015 Oil & Gas Institute
Jackson Walker Represents Freeman Group in Series A Investment in Pixia Corp.
Jackson Walker Represents Freeman Group in Acquisition of By George
Byron Egan, Willie Hornberger, Steve Moore Speak on Choice and Acquisition of Entities
Jackson Walker Attorneys Participate in Whitley Penn Energy Seminar
IRS: Investment Fund Managers are Subject to Self-Employment Tax
Jackson Walker Congratulates Its Best Lawyers in America 2015
Cale McDowell, William Hornberger, Steve Moore and John Ransom Speak at Texas Society of CPA’s Oil & Gas Seminar
Byron Egan, William Hornberger, Steve Moore Speak on Choice and Acquisition of Entities
Willie Hornberger and James Prappas Speak at International Tax Forum
Willie Hornberger Featured on Cover of Today’s CPA Magazine
Willie Hornberger and James Prappas Speak on International Taxation and U.S. Immigration
Byron Egan, Willie Hornberger, & Steve Moore Speak at the State Bar of Texas Choice and Acquisition of Entities in Texas Course
Steve Moore and Ashley Scheer Speak at Convergence 2013
Jackson Walker Congratulates Its 2013 Best Lawyers in Dallas
Jackson Walker Represents Select Milk Producers in Joint Venture with The Coca-Cola Company
Jackson Walker Nationally Ranked in 23 Areas in ‘Best Law Firms’ Guide
Jackson Walker Congratulates Its Best Lawyers "Lawyers of the Year"
Bryon Egan, Willie Hornberger and Steve Moore Speak at the State Bar of Texas Choice and Acquisition of Entities in Texas Course
Willie Hornberger Named Chairman-Elect of Texas Society of CPAs
“Common Tax Issues for Companies New to the U.S. Market”, SelectUSA Investment Summit Academy, Washington, D.C., June 2018
“Entity Selection for the M&A Lawyer”, ABA Business Law Section Spring Meeting, Orlando, Florida, April 2018
“Entity Selections, Exchanges & Formations”, Texas CPA Tax Institute, Richardson & San Antonio, Texas, November 2017
“What Every Director Needs to Know about the 990”, The University of Texas at Dallas Nonprofit Conference, Dallas, Texas, October 2017
“Comprehensive Inbound/Outbound International Taxation”, Texas A&M Law School, Fort Worth, Texas, October 2017
“International Taxation”, 8-hour course, Rio Grande Valley Chapter of Texas Society of CPAs, October 2017
“Selected Structuring Considerations For Foreign Persons Establishing U.S. Business Operations, U.S. Embassy Luncheon, Lausanne Switzerland, September 2017
“Tax Consideration in Entity Choice”, University of North Texas Presentation, September 2017
"Tax Reform Update," Instituto de Contadores Públicos de Nuevo León A.C (ICPNL), August 2017
“Alternativas Fiscales para Inversiones en EUA”, Instituto de Contadores Publicos de Nuevo Leon, Monterrey, Mexico, August 2017
“Structures for Acquiring Entities Federal & State Tax Consequences” Tax Institute CPE, Fort Worth, Texas, August 2017
“Partnership Agreements – Debt Issues”, Metroplex Practice Management Group, Dallas, Texas, July 2017
“Selected Considerations for Foreign Nationals Moving to the U.S.”, SelectUSA Investment Summit Conference, U.S. Department Washington, D.C., June 2017
"Choice of Entity," State Bar of Texas, Choice & Acquisitions of Entities in Texas Course, May 2017
"International Taxation”, 8-hour course, El Paso Chapter, Texas Society of CPAs, May 2017
“Accounting for Change: The Accounting Profession Will Thrive in the Current Economic, Tax and Political Environment, TSCPA Energy Conference, May 2017
“Tax Aspects of Workouts and Bankruptcies in the Oil Patch”, North American Petroleum Accounting Conference, May 2017
“Selected Tax Considerations for Entity Selection”, Financial Executives International, Dallas, Texas April 2017
“International Taxation”, 8-hour course, San Jose, California ARM, Inc. (January 2017)
"Defining your Legacy: Serve Well/Lead Well," Beta Alpha Psi Accounting Regional Conference, March 2015
"Careers with a CPA," Incarnate Word University, April 2015
"Choice of Entity," State Bar of Texas, Choice & Acquisitions of Entities in Texas Course, May 2015
"Motivating and Developing Others," Leadership Acadamy, Dallas CPA Society, June 2015
Guest Lecturer, Baylor University International Tax Course, October 2015
"International Taxation," Dallas CPA Society Continuing Education Conference, February 2014
"U.S. Immigration & Tax - Opportunities and Pitfalls", International Tax Forum Meeting, March 2014
"U.S. Immigration & Tax - Opportunities and Pitfalls", International Tax Forum Meeting, March 2014
"Choice of Entity," Dallas Estate Planning Council, May 2014
"International Taxation," 8 hour course taught for El Paso Chapter of the TSCPA, May 2014
"Choice of Entity," State Bar of Texas, Choice & Acquisitions of Entities in Texas Course, May 2014
"International Taxation," CPE by the Sea Continuing Education Conference, June 2014
Oil & Gas Institute - Full-Day Oil and Gas Conference, July 2014
"Texas Business Update," 20th Anniversary U.S./Mexico Tax Conference sponsored by the San Diego Chapter of the California Society of CPAs and Colegio de Contadores Publicos de Baja California, August 2014
"Earnings Lockout and Inbound M&A" UT/University of Waterloo Conference for Accounting Professors in North America, September 2014
"The Future of Business Valuation, Forensic & Litigation Service," Business Valuation and Forensics Conference, October 2014
"International Taxation," ARM, Inc., November 2014
"International Taxation," Reforma Energica Conferencia, November 2014
"International Taxation," U.S./Mexico Conference, November 2014)
"Texas Margin Tax," American Association of Attorney-Certified Public Accountants, January 2013
"Tax Environment," East Texas Business Conference, Texas A&M Commerce, April 2013
Luncheon Keynote Speaker, Joint Meeting Lamar University School of Accounting and South East Texas Chapter/TSCPA, April 2013
Luncheon Keynote Speaker, Brazos Valley Chapter of the Texas Society of CPAs, May 2013
"International Taxation," 8-hour course for El Paso Chapter of the Texas Society of CPAs, May 2013
"Motivating and Developing Others," Dallas CPA Society Leadership Day, May 2013
"Tax Considerations In Choice of Entity," State Bar of Texas, Choice of Entity & Acquisitions Course, May 2013
"International Taxation," Houston Chapter of the Texas Society of CPAs, June 2013
Speaker, Young CPA Conference, Texas Society of CPAs, June 2013
Luncheon Keynote Speaker, Annual Two-Day Tax Institute, Panhandle Chapter of the Texas Society of CPAs, August 2013
"The Accidental U.S. Taxpayer," State Bar of Texas Advanced Tax Law Course, August 2013
Luncheon Keynote Speaker, Abilene Chapter of the Texas Society of CPAs, August 2013
"Professional Issues Update," Lubbock Chapter of the Texas Society of CPAs, September 2013
"Professional Issues Update," Webinar, September 2013
"Motivating and Developing Others" Dallas CPA Society Leadership Academy, September, 2013
"International Tax Update," Dallas Bar Association, October 2013