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James Howard focuses his practice in the area of international and corporate tax, corporate finance, and securities. Education J.D., South Texas College of Law, 1994 B.A., Oklahoma State University, 1991 Bar Admissions Texas, 1995 Representative Experience U.S. Taxation of International Operations and Foreign Persons US-based technology company repatriating earnings from European subsidiaries U.S. public retailer disposing of its Mexican operations European bank loaning to US persons Mexican corporation forming a partnership to acquire and develop technology with U.S. owner of technology U.S. partnership issuing partnership interests to investment fund from India U.S. partnership complying with US tax filing obligations relating to interests therein being owned by foreign persons U.S. real estate company disposing of real estate in Belgium Jamaican-based telecommunications outsourcing company Nutritional supplement manufacturers structuring international sales and distribution and related transfer of intellectual property relating thereto Cayman-based corporations owned by non-U.S. persons engaged in the U.S. oilfield services industry Australian bank acquiring U.S. utilities A number of families owning interests around the world on U.S. tax consequences of operations and repatriation of income therefrom U.S. manufacturer owned by foreign persons Assisted management on joint venture with publicly-traded French corporation to provide logistics for oil exploration in African countries Tax advice to publicly traded U.S. company on going private transaction pursuant to purchase by European corporation Mexican-based telecommunication company on investment in U.S. joint venture Publicly traded U.S. services company structuring debt of its Canadian subsidiaries Publicly traded U.S. chemical company proposing joint venture in China Oilfield services company acquired by Australian buyer U.S. Taxation of Domestic Operations and U.S. Persons Tax and partnership advice to joint venture company constructing one of the largest natural gas pipelines ever built in North America Commercial real estate manager in forming joint venture to redevelop existing shopping center in central Texas Management forming partnership with equity fund sponsor to purchase Gulf of Mexico blocks from major global energy company and structure the company’s incentive compensation plans General tax advice to a number of private equity funds on structuring its portfolio investments General tax advice on proposed mergers and acquisitions to a number of publicly traded partnerships (i.e., MLPs) Corporate and tax advice to a large, private oilfield services company in selling a portion of equity to a financial purchaser. Tax advice on securities offerings and mergers and acquisitions for publicly-traded integrated energy company Tax advice to corporation in connection with numerous reorganization transactions to preserve net operating losses and certain related favorable tax attributes General tax and business entity advice to numerous U.S. investment groups on real estate investments and developments Tax advice to financial institution serving as trustee of fund holding demutualization proceeds of employee benefit plan Advice management of private E&P company in selling equity to equity fund Numerous reorganizations of Texas companies to minimize state income taxes Real estate developer obtaining tax-exemption for country club General Corporate and Tax Advice Structure intercompany transactions regarding tax considerations and create equity-based incentive compensation plans for privately-held financial institution General corporate and tax advice to a family-owned real estate company owning apartment properties in and around Houston Technology company implementing a reverse-split to reduce the number of the company’s shareholders OCTG distributor and other oilfield service companies Publications & Presentations Inconsistent Decisions in Recent Tax Shelter Cases, 29 The Texas Tax Lawyer (Feb. 2002) Supreme Court Reverses Trend; Holds Only Clients Can Sue Attorneys, 60 Tex. Bar J. 208 (March 1997) Property Contribution to Satisfy Pension Funding Obligations Results in 100% Excise Tax Under ERISA Keystone v. Comm’r., 113 S. Ct. 2006 (1993), 12 Corp. Counsel Rev. 237 (November 1993) Press Release Locke Liddell & Sapp Elevates 11 Associates to Partners 12/12/2005 Professional History Partner in the law firm of Locke Liddell & Sapp Professional Affiliations State Bar of Texas (Sections of Taxation and Corporate Counsel) Chair, Partnership & Real Estate Tax Committee Member, International Tax Committee Member, Subcommittee on Corporate Tax Shelters, Corporate Tax Committee Houston Bar Association International Tax Forum of Houston. | 