Jessica Hough

Jessica A. Hough
Partner, Tax
While Ms. Hough has a broad-based M&A tax practice across various industries, she also advises clients in the financial services sector on insurance-related corporate transactions, including capital raising, mergers and acquisitions, reinsurance 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 Corporation; FBL Financial; Jackson National Life; Liberty Mutual Insurance Company; MetLife, Inc.; Pacificare Health Systems; ProMutual Group; Safeco Corporation; SCOR SE; Selective Insurance Group; Travelers Property Casualty Corp.; UnitedHealth Group Inc.; and Validus Holdings, Ltd.

Ms. Hough also is consulted regularly on tax matters related to corporate restructurings. She has represented a number of clients in connection with restructurings involving tax-free spin-offs, including Duke Energy Corporation in its spin-off of Spectra Energy Corp., Temple-Inland Inc. in its spin-offs of Guaranty Financial Group and Forestar Real Estate Group, and Applied Biosystems Inc. in its split-off of Celera Corporation.

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, cross-border financing transactions, business valuations and other transactions.

Ms. Hough’s other notable tax matters include the representation of The AES Corporation; Alcoa, Inc.; Alpha Industries, Inc.; Applied Biosystems Inc.; Arcelor Mittal; Biogen, Inc.; BJ Services Company; Celanese AG; Cooper Industries; Daimler AG; Duke Energy Corporation; Electricité de France; EQT Corporation; EMC Corporation; Ford Motor Company; GenOn Energy, Inc.; Houghton Mifflin Company; Northeast Utilities; Scripps Networks Interactive; Spectra Energy Corp.; and U.S. Airways, Inc.

In addition to her thriving practice, Ms. Hough is very active in promoting diversity in the legal profession. She is a member of the firm’s Women’s Initiatives Committee and a board member of Women in Law Empowerment Forum. She co-chaired the ABA Tax Section Diversity Committee, and is a recipient of the Nolan Fellowship, which is awarded to young lawyers who are actively involved in the Section and have shown leadership qualities. She also was a 2011 fellow in the inaugural Leadership Council on Legal Diversity Fellows Program for which she mentors incoming minority students at law schools in Washington, D.C. Ms. Hough repeatedly has been selected for inclusion in Chambers USA: America’s Leading Lawyers for Business, The Legal 500 U.S. and also has been named in International Tax Review’s “Women in Tax Leaders” supplement. She also was named as one of Law360’s 14 Influential Women In Tax Law in 2019 and repeatedly has been included in Washingtonian’s Top Lawyers list.