Julio M. Jimenez
Adjunct Professor of Law
Julio Jimenez recently joined PWC's Banking and Capital Markets International practice in New York City. Previously, he had joined EY's ITS Capital Markets in the...Continue Reading
Julio Jimenez recently joined PWC's Banking and Capital Markets International practice in New York City. Previously, he had joined EY's ITS Capital Markets in the National Tax Department in June 2011 from the Office of Chief Counsel for the IRS, where he had spent the previous five years working in the National Office for the Division Counsel of LB&I. Mr. Jimenez's specialties involve debt, financial products, foreign currency, foreign banking and cross border financing. During his tenure in Division Counsel for LB&I, Mr. Jimenez worked closely with a number of executives in Chief Counsel, the IRS and Treasury regarding debt matters, including debt v. equity considerations, sourcing cancellation of indebtedness income, distressed debt and bad debt deductions in the banking, insurance and REMIC context. Mr. Jimenez also worked closely on matters including the taxation of options, forward contracts, including prepaid forward and variable prepaid forward contracts, notional principal contracts, including credit default swaps and other contingent non-periodic swaps, hedging transactions, mixed straddles, and a host of other issues involving the taxation of derivatives including swaptions, securitization issues, section 475 issues and equity swaps. Mr. Jimenez also worked on a number of cross border financing and baking issues, including foreign currency matters under sections 988 and 987, subpart F considerations on hedging transactions and financing arrangements under section 956, sections 163(j) and 267 interest deduction limitations, sourcing and general withholding matters including dividend equivalent withholding and securities lending transactions, as well as lending into the U.S. as a trade or business, conduit financing arrangements, and treaty taxation of foreign banks and global dealing operations. Mr. Jimenez was actively involved in drafting the Industry Director Directive on dividend withholding on total return swaps, and was also involved in AM 2009-010 on hedge fund lending into the U.S., Notice 2010-46 on cascading withholding, AM 2010-005 on option baskets, and the section 871(m) regulations, Notice 2010-46 on securities lending, along with a number of other publications. He graduated with honors from Boston College, has his J.D. with honors as a Law Journal Executive Technical Editor from New England Law, and his LL.M. in Taxation from Georgetown Law Center.