Sarah-Jane Morin focuses her practice on representation of public and private companies, private equity funds, venture capital funds, real estate funds, portfolio companies, and alternative investment vehicles in the tax aspects of complex business transactions and fund formations, including domestic and cross-border investment strategies, sponsor investment strategies, limited partner investment strategies, mergers, acquisitions, integrations, buyouts, recapitalizations, debt and equity restructurings, and ongoing operations and tax compliance issues. Additionally, she advises on international tax issues, including the tax aspects of offshore vehicles (CFC/PFIC/GILTI regimes), anti-deferral rules (Subpart F), withholding, cost sharing, and transfer pricing.
Sarah-Jane advises on the tax aspects of non-profit entity formation and operation, with an emphasis on IRC Section 501(c)(3). She has worked with a number of tax-exempt investors in their LP investments, as well as for clients in their applications for tax exemption.
Prior to joining Morgan Lewis, Sarah-Jane was a senior director in Oracle’s tax planning department. Prior to joining Oracle, she was an associate at a multinational law firm.
University of California, Berkeley School of Law (Boalt Hall), 2009, J.D.
University of California, Berkeley, 2004, B.A., National Society of Collegiate Scholars, Order of Omega Honor Society
Awards and Affiliations
Recommended, Tax: US taxes: contentious, The Legal 500 US (2019)
Recommended, Tax: US taxes: non-contentious, The Legal 500 US (2019)
Member, Tax Authority: Federal, US Editorial Advisory Board, Law360 (2019)
Member, San Francisco & Silicon Valley Tax Firm of the Year, International Tax Review (2018)
Member, Practice Group of the Year, Tax, Law360 (2017)