Jessica A. Hough

Partner, Washington, D.C. Tax

Jessica Hough, head of the firm’s Washington, D.C. office, represents clients on a wide range of tax matters, with particular emphasis on mergers, acquisitions and divestiture transactions, including spin-offs, debt and equity offerings, corporate and partnership restructurings, and joint ventures.

While Ms. Hough has a broad-based M&A tax practice across various industries, she also advises clients in the sector on -related corporate transactions, including capital raising, mergers and acquisitions, transactions, restructurings and related matters. She has extensive experience in the U.S. and international insurance and reinsurance industries, having represented numerous industry participants in all lines of business, including life, health, property and casualty, and specialty lines. In recent years, Ms. Hough has worked on insurance-related tax matters for Aflac Incorporated; Cigna T: 202.371.7054 Corporation; FBL Financial; ; Insurance Company; F: 202.661.8292 MetLife, Inc.; Pacificare Health Systems; ProMutual Group; Safeco Corporation; SCOR SE; [email protected] Selective Insurance Group; Travelers Property Casualty Corp.; UnitedHealth Group Inc.; and Validus Holdings, Ltd.

Education Ms. Hough also is consulted regularly on tax matters related to corporate restructurings. She J.D., The University of Chicago has represented a number of clients in connection with restructurings involving tax-free spin- Law School, 1997 offs, including Duke Energy Corporation in its spin-off of Spectra Energy Corp., Temple-In- M.P.A., The University land Inc. in its spin-offs of Guaranty Financial Group and Forestar Real Estate Group, and of Texas at Austin, 1993 Applied Biosystems Inc. in its split-off of Celera Corporation. B.B.A., The University of Texas at Austin, 1993 In the tax controversy area, Ms. Hough has advised clients on a wide range of matters during all phases of IRS audits and appeals, including matters involving leasing, the economic substance and business purpose doctrines, the tax treatment of financial instruments, Bar Admissions cross-border financing transactions, business valuations and other transactions. District of Columbia Ms. Hough’s other notable tax matters include the representation of The AES Corporation; Experience Law Clerk, Hon. Joel Gerber, Alcoa, Inc.; Alpha Industries, Inc.; Applied Biosystems Inc.; Arcelor Mittal; Biogen, Inc.; U.S. Tax Court (1999-2000) BJ Services Company; Celanese AG; Cooper Industries; Daimler AG; Duke Energy Corpo- ration; Electricité de ; EQT Corporation; EMC Corporation; Ford Motor Company; GenOn Energy, Inc.; Houghton Mifflin Company; Northeast Utilities; Scripps Networks Publications Interactive; Spectra Energy Corp.; and U.S. Airways, Inc. Co-Author, “Certain Tax Issues in M&A Transactions Involving Insurance In addition to her thriving practice, Ms. Hough serves on Skadden’s governing body, the Companies,” Practising Law Institute Policy Committee, and is very active in promoting diversity in the legal profession. She (2011-2018) co-chaired the ABA Tax Section Diversity Committee, and is a recipient of the Nolan Co-Author, “IRS No-Rule Policy Fellowship, which is awarded to young lawyers who are actively involved in the Section and Will Increase Reliance on Opinions,” have shown leadership qualities. She also was a 2011 fellow in the inaugural Leadership Law360, February 7, 2014 Council on Legal Diversity Fellows Program for which she mentors incoming minority Co-Author, Chief Executive Legal students at law schools in Washington, D.C. A frequent author and speaker on a wide range Guide, Chief Executive Research, 2012 of tax matters, Ms. Hough has repeatedly been selected for inclusion in Chambers USA: America’s Leading Lawyers for Business and The Legal 500 U.S. She also was named by International Tax Review as its 2020 North America Tax Practice Leader of the Year, as well as by Law360 as one of its 2020 Tax MVPs and one of its 2019 Influential Women In Tax Law.

1 Skadden, Arps, Slate, Meagher & Flom LLP