0:01

Taxpayers , real estate developers, entrepreneurs,

0:03

investors, advisors , et Cetera , are starting

0:05

to get more comfortable with the rules. And with that

0:07

perhaps starting to get a little bit more ambitious with their

0:09

investment in planning. Do

0:13

I want to go into this kind of career, that kind of career.

0:15

And I thought economics and philosophy was a it's

0:18

an interesting combination to maybe expose

0:21

me to the idea that really ran

0:23

the gamut from one end of the spectrum to

0:25

the other.

0:27

Welcome back everyone. It's the OZExpo podcast.

0:30

I'm your host Jack Heald . And joining

0:32

me today is Jon Talansky who

0:35

is a partner at the law firm of King

0:37

and Spalding. John , welcome to the

0:39

OZExpo podcast.

0:41

Thank you Jack. Good to be here.

0:43

So real quickly, when

0:45

I did my research I discovered

0:48

that King and Spalding is a pretty good size

0:50

organization. I've never heard of it. Tell

0:53

us a little bit about King and Spalding and

0:55

your role there.

0:57

Sure. King and Spalding is a

1:00

large corporate and litigation

1:02

focused law firm. We're over a hundred

1:04

years old. Our first office was open

1:06

, then Atlanta, Georgia, ah

1:08

, before the turn of the 20th century.

1:10

In fact with

1:12

some, originally some Atlanta based southeast

1:15

based clients such as Coca-Cola . and

1:18

I guess for the better part of the

1:22

last century and a half or so , we've grown too something

1:24

in the ballpark of 1100 lawyers. We have offices

1:27

and many countries

1:29

throughout the United States on both coasts, Chicago,

1:32

Houston, DC.

1:35

and I sit in the New York office. I'm a partner

1:37

in our tax group. One of

1:40

the things I focus on is real estate. And we have

1:42

over 200 lawyers in our firm focused

1:44

on the real estate industry. Okay . Well

1:46

all parts of the life cycle of the real estate industry,

1:49

private equity, fundraising, dirt

1:51

transactions, 10 31 transactions,

1:53

a real estate finance. And now

1:55

I'd say since the advent of tax reform, we've

1:58

developed a sub-specialty and opportunity

2:00

zones, which really, really

2:03

, really coalesces a lot of the expertise

2:07

areas that we, that were really good with. So

2:09

that's, that's a bit about King and Spalding.

2:12

How long have you been with the company?

2:14

I've been with the company almost four years now.

2:17

Okay. And

2:19

it looks like you got your JD

2:21

at Harvard and a BA at Columbia

2:24

in economics and philosophy. I'm going to

2:27

circle around later on and ask you some questions

2:29

about that, because those are two things

2:32

that I'm interested in. But we're not going to do

2:34

that right now. So let's, let's talk about

2:36

opportunities zone s work

2:38

specifically as a lawyer. You're going to be

2:40

the guy who clients ask

2:42

about where

2:45

are the hurdles, where are the speed bumps,

2:47

where are the

2:50

tar pits that we have to avoid. What's

2:54

some of the tough questions

2:57

that have arisen with this new

2:59

legislation?

3:03

I think that's , that's a perfect place to start.

3:05

I think as from my vantage

3:07

point speaking tool and working with

3:09

a lot of clients and working over

3:12

upwards of, yeah , 25, 30

3:14

transactions all over the u s right now,

3:16

I think tax payers

3:18

, real estate developers, entrepreneurs, investors,

3:22

advisors , et Cetera , are starting to get more comfortable with

3:24

the rules. And with that perhaps starting

3:26

to get a little bit more ambitious with their investment planning.

3:28

And I think as

3:32

we progress in this first generation of opportunities

3:34

on deals, I think both from a real estate perspective

3:37

and an operating business perspective. People

3:39

are starting to find challenges

3:42

in some of these interpretive questions that have arisen under

3:44

the rule.

3:45

So I'll pick one from each of the broad categories.

3:47

I like to think of the

3:49

Opportunity Zone marketplace as first

3:51

real estate development, which is obviously I

3:54

think too many , the first area

3:56

that really hit the ground

3:58

running after the Opportunity Zone rules were

4:00

promulgated. The

4:04

fixed location nature of real estate

4:06

and the fact that the rules seem to lend themselves

4:09

quite well towards real estate development projects,

4:11

I think is largely a explains

4:13

why real estate was the first industry to really pick

4:15

up on these rules. And in that. In that

4:17

sense, I think early on we saw a lot of deals

4:19

that were more finite, more limited people

4:22

try to give an opportunities on overlay to projects

4:25

that they were working on already or deals

4:27

that they had circled.

4:28

But as we've moved forward, I think a lot of the real estate

4:30

investors that I speak to, as

4:32

I said, are getting a little bit more ambitious and are trying

4:35

to raise capital

4:38

and develop longer

4:41

term, multi-phase master plan projects

4:43

around the opportunities on roles . And I think one of the challenges

4:45

that they're finding is that it's really not clear when

4:48

you look at the rules and all of their, all

4:51

of their nuances, whether these rules

4:53

really fit perfectly with a longterm

4:55

- and when I say longterm , I'm talking

4:57

about let's say a multi-phase project

5:01

that might have up

5:03

to a year or two of entitlement work to be done, plans

5:06

to be drawn up. And then a long build

5:08

period that might take you out let's say even

5:10

as much as four or five years from the time

5:13

of the initial equity raise for

5:15

reasons that might be deliberate and might just

5:17

be accidental. The rules do

5:19

contemplate a degree of business

5:21

activity and degree of you know,

5:23

quote unquote unit delivery by

5:26

the end of a let's say two and a half year runway,

5:29

this 30 or 31 month period and sweet spot

5:31

that a lot of people think of or , or are

5:34

aware of when they, when they look at the rules. And

5:36

I think the question is what about projects that might

5:38

have a little bit of a longer lifespan ? Raises,

5:41

I think policy questions and then just

5:43

legal questions. I think that's on the real estate side.

5:45

One of the challenges that people are focused on on

5:47

the, what I'd call the operating business side,

5:51

more operating business focused

5:53

entrepreneurs who clearly are also in

5:56

the the sweet spot

5:58

of these rules and certainly were what the policy makers

6:00

were thinking of when they thought about moving jobs

6:02

to these low income areas. I'm

6:05

in need of investment.

6:08

I think the struggle that they're having is in the new

6:10

economy. There's so many businesses that are nimble and

6:12

that are not asset heavy but that rely on

6:14

intellectual property and software and other

6:16

types of innovative business models. And it's

6:18

not perfectly clear when you read the rules

6:21

that they're perfectly suited or at least so

6:23

easily applied when it comes to those types of

6:25

businesses. So as I get phone calls from the real estate

6:28

developers who are thinking large scale big

6:30

projects and the entrepreneurs who might have a

6:32

software idea or might have a patent that they're looking to

6:35

license, I think that's where the biggest challenges are coming now.

6:37

under these rules.

6:39

Yeah . Let's go back to the real estate

6:41

development. These long term

6:43

projects with a three year

6:46

build out. How

6:48

are you - and I'm not asking you to give away

6:51

free legal advice here - but how are you

6:54

addressing that with your clients? What's

6:57

your opinion and

6:59

perspective on this?

7:02

Well, I start almost all discussions

7:04

with, with my clients with okay.

7:08

No prefatory comments to make sure that the client,

7:11

this is a unique area. Normally I don't care

7:13

that my clients understand or don't understand

7:15

the policy behind the particular rule or

7:18

tax structure that we're pursuing. This area

7:20

is somewhat unique in that I think clients ought

7:22

to understand that, that the purpose behind these rules,

7:25

okay , is what it is. And the

7:28

, the purpose itself is somewhat, it's

7:30

somewhat elusive. It's not perfectly clear. It's not

7:32

really articulated anywhere in any sort of discreet

7:34

, concise manner. However, I

7:36

think it's important that clients and taxpayers understand

7:38

that ultimately if a project is

7:40

going to be audited and it's going to be looked at by the tax

7:43

authorities, by the IRS, the

7:45

one of the policies clearly animating these roles

7:48

is to bring commercial activity and

7:50

for development and move jobs into these

7:52

neighborhoods. So I think it's important

7:54

that clients understand that because there's an

7:56

anti abuse rule in the reg. So even if you can

7:58

check every box and run every trap

8:01

and meet all the requirements that are there in black

8:04

and white and the rule, I think it's important for people to understand

8:06

that as long as you are working with all deliberate

8:08

speed towards some goal that

8:11

can ultimately demonstrate moving economic

8:13

activity into a neighborhood, it might be in

8:15

a better place. In terms of the specific questions,

8:17

what I'm telling clients is that it's important

8:20

to consider tweaking a

8:22

business plan, perhaps introducing

8:25

a certain commercial elements to a development

8:27

plan. No building access roads,

8:29

pre-leasing activities things

8:32

like that that you might not otherwise do

8:34

if there were no tax restrictions. But given that

8:36

it's important to demonstrate at

8:39

some time within let's say the two to three

8:41

year period, some degree of economic

8:43

activity to try to see if those types

8:45

of revenue generating activities

8:47

or commercial activities can actually be

8:50

introduced into the process at some point

8:52

before the end, before it gets too

8:54

late. That's , that's really how I'm handling

8:56

it. And then obviously every project presents

8:59

its own facts and challenges. So

9:01

it's really a case by case basis.

9:03

Yeah, that makes sense. What

9:05

about the problem

9:07

with intellectual property, I know that

9:09

the April Regs, the second round

9:12

of regulations that came out in April helped

9:14

in that regard a little bit, but

9:17

I'd appreciate it if you'd talk a little bit more

9:19

about how that

9:22

second set of regulations clarified

9:25

these operating businesses that might

9:27

not necessarily be like a manufacturing

9:29

business. It's got equipment and

9:31

capital equipment and, and

9:33

lots of people sitting in a particular location

9:36

all the time.

9:38

Sure. I

9:41

think in many respects, the April regulations were

9:43

extremely helpful and obviously

9:45

embodied a general

9:49

the general approach of liberalizing the rules.

9:51

And making it easier as opposed to harder for

9:53

businesses to take advantage and potentially move

9:56

their , their core people on their core assets into the zones.

9:58

So for example, the gross income requirement,

10:01

which we don't have to go through at chapter and verse, but

10:03

basically the gross income requirement requires

10:05

50% of the income of the

10:07

business to be generated from, from, from a

10:09

trade or business and active conduct of

10:11

that business. And in the opportunities on

10:14

in that area, the IRS and the

10:17

regulations promulgated three

10:19

very helpful safe harbors that

10:21

I think have been,

10:23

have been well publicized and written about

10:25

and discussed in many, in many forum

10:28

. and there's also

10:30

after the three safe harbors, there's a general facts and

10:32

circumstances test. So I think if you apply the safe

10:34

harbor as the most businesses, a

10:36

lot of business owners and entrepreneurs and venture

10:39

capital investors can get comfortable with respect

10:41

to the intellectual property.

10:42

There's a separate requirement that the

10:44

government in one respect

10:47

helped us on, but in another respect stayed silent

10:50

on. And that is that the, under the statute,

10:52

the requirement is that a substantial portion

10:54

of the intellectual of the intangible property

10:56

of the business, which in many cases will take the form

10:58

of IP and other intangible

11:01

assets be used in the business.

11:04

What the April regulations did was defined substantial

11:06

portion for those purposes as 40%, which

11:08

you might think is a generous kind of

11:10

low bar to meet. The

11:12

problem is that locating

11:15

the, the, the, the, the locus really

11:17

of intellectual property or other intangible assets

11:19

itself is an elusive concept. We have other

11:22

areas in the tax law where we have specific

11:24

rules that tell us how

11:27

to determine where the location of intangible

11:29

property is or more precisely where the source

11:31

of income is that that is generated by

11:33

the intellectual property.

11:36

In the OpZone space, there's no specific rules in that regard. So even

11:38

though we've had, we have this helpful standard that says that

11:40

40% of your intangible

11:42

assets have to be used in the business and the zone.

11:45

Of course when you apply that to a lot of the

11:48

modern day businesses, which might have a good chunk

11:51

of intangible assets such as patents,

11:56

licenses, goodwill other

11:59

IP. It can be difficult

12:02

to , to, to advise clients with absolute certainty

12:04

that they'll be able to pay to meet the test. So I think

12:07

it would be nice if , if future guidance

12:09

or when the regs are finalized or in some other form,

12:12

we have a little bit more meat on the bone in terms

12:14

of how taxpayers should be thinking about that

12:16

requirement. Especially because so

12:18

many of the businesses in the new economy

12:21

no rely heavy on as

12:23

opposed to relying heavily on core tangible

12:26

assets. a good bulk of their value

12:28

is in intangible property.

12:30

Yeah . Let's take

12:32

a slight turn here.

12:35

I've see on - what

12:37

was it Monday? Monday the

12:39

SEC issued a statement addressing

12:42

compliance for qualified opportunity

12:44

funds. Can you explain that to

12:46

us?

12:49

Well, I am a tax lawyer and not a securities

12:51

lawyer. I think my

12:53

colleagues and I did look at that statement that was

12:55

put out by the SEC. And

12:57

I think above all the takeaway from that guidance

12:59

, anybody who's listening or

13:02

tax payers out there certainly consult with their

13:05

local securities law expert , whether

13:07

it be a King and Spalding or somewhere else. But I think the takeaway

13:09

from there is that the SEC and

13:11

the other regulators are definitely, definitely

13:14

seem to be very focused on

13:16

Opportunity Zones as

13:19

a fundraising strategy, precisely because

13:22

the nature of the investors here is overwhelmingly likely

13:27

to be your two legged retail, potentially

13:30

high net worth. And to a lesser degree

13:32

institutional investors. And I think it's

13:34

been a long standing tradition with the SEC

13:36

to look with a little bit more scrutiny at fundraising

13:39

when it comes to retail type investors

13:42

or being pitched fund

13:45

raising ideas and strategies on a

13:47

large scale basis. So I think what the key

13:49

takeaway from the SEC statement, it

13:52

was just that the IRS is not

13:54

going to apply any special exceptions

13:56

or rules to fundraising or SEC

13:58

registration requirements or

14:01

exemptions when it comes to qualified opportunity

14:03

fund fundraising and that

14:06

advisors should

14:08

be aware of that and should keep those rules

14:11

handy and close by when advising clients

14:13

on how to go raise money under one of these

14:15

strategies.

14:17

All right . Very good. I appreciate that.

14:20

I also

14:22

noticed that you seem to have a good deal

14:24

of interest in the renewable energy

14:27

sector. I know there's lots

14:29

of tax mitigation opportunities

14:32

in that sector. Are there

14:35

specific opportunities for OZ investors

14:39

with renewable energy?

14:43

I think yes

14:45

and no. Renewable energy is an area

14:47

that I think financing it has always

14:50

been really the key

14:51

hurdle and the key

14:53

challenge. And I think that's why you

14:55

see it's so commonplace in the market, whether it be

14:58

renewable or traditional electricity and power.

15:01

All kinds of tax equity and tax credit

15:04

structures. Because I think

15:06

oftentimes the regular way

15:10

fundraising and financing of these projects

15:12

won't necessarily get a project

15:14

sponsor developer to where they need to get to. And that's

15:17

why tax equity and tax credit

15:19

structures have been so prominent.

15:21

I think therefore the

15:24

Opportunity Zone rules are somewhat unique in

15:26

that they do potentially offer these sponsors

15:28

and developers an alternative or a new

15:30

way to raise capital. It wouldn't

15:32

be in lieu of the traditional types of renewable

15:34

energy investors. I think it could however,

15:38

take up a portion of the capital stack that

15:40

might otherwise have been reserved

15:42

for other , perhaps more, perhaps less

15:45

exotic types of financing. The

15:47

other thing I'd note as well as that the

15:50

nature of these

15:54

types of projects typically

15:56

are such that building

15:59

a project in an area, for example, in

16:01

a rural environment or rural neighborhood

16:03

or rural area might be easier than

16:06

somebody who might have some other type of retailer

16:08

mixed use strategy that wouldn't necessarily

16:11

be amenable to obviously building the project

16:13

just anywhere. You need to build it in the strategic

16:16

place or neighborhood that provides

16:18

some of these advantages. Whereas renewable

16:20

energy as a self contained

16:23

electricity or power producing enterprise

16:27

might be a little bit more flexible in terms of selecting

16:29

the location of such a plant and therefore

16:32

a place based tax incentive like this, which

16:34

might, if you look at a map, cover urban

16:37

areas, suburban areas and swaths

16:40

of land in rural America might

16:42

offer interesting opportunities for

16:44

renewable energy developers that might be

16:48

fewer and farther between for

16:51

more typical traditional multifamily

16:54

or hotel or

16:56

a retail developers. So I think in

16:59

those ways we're still trying to figure

17:01

it out. We're still trying to figure out if the economics

17:03

of these deals works from an opportunity zone perspective

17:06

and if there's enough tax incentive out there to attract

17:08

these investors. But I think there are certain

17:10

potential advantages out there that

17:12

we are likely to see.

17:15

You used a phrase that I have

17:17

not heard before that

17:20

I would like you to explain. In

17:22

the context of talking about tax credit

17:25

as part of the

17:27

finance stack, use the term "tax

17:30

equity." What does that mean?

17:32

So tax equity is really a term of art.

17:35

It's not a new concept. Tax Equity essentially

17:37

relates or refers to

17:40

investors in projects that

17:43

generate, due to certain statutory

17:46

tax credit regimes, the ability

17:48

to tax credits as reductions

17:51

or offsets to what otherwise would be a tax liability.

17:54

Traditionally sponsors of projects like

17:56

this wouldn't necessarily have

17:59

the appetite or the capacity to utilize

18:01

those tax credits that the project is generating

18:04

as much as say an insurance company or

18:07

some other institutional investor that, for example,

18:09

has a lot of income that can absorb these

18:11

tax credits would have it.

18:13

So it's been a rather l ongstanding structure.

18:16

Would t hese developers go out and go out to

18:18

a select number of tax

18:20

equity, quote unquote tax equity investors

18:23

to invest in the projects? A good

18:25

chunk of the return, the rate of return

18:27

that in a normal project would take the form of

18:29

just a cash on cash return and a traditional

18:32

IRR, in these types of projects,

18:34

a good chunk of the return actually is delivered to these

18:36

investors through an allocation of tax credits.

18:39

Okay. That makes sense. So basically

18:42

the developer is exchanging

18:46

his tax credit for

18:49

equity in the company, correct?

18:53

Correct. I mean, they can

18:55

be inordinately complicated. The

18:59

IRS has put out guidance over the

19:01

years with guardrails

19:03

around how

19:07

easy it is to allocate

19:10

tax credits to investors who might not otherwise

19:13

participate in or own otherwise

19:16

the economics i n the project. Developers

19:19

and sponsors a nd their a dvisors have gotten pretty good

19:21

at staying within the four

19:23

corners of that guidance and running

19:25

permissible tax equity investment

19:29

projects to deliver these tax

19:32

credit- b ased returns to the investors and I

19:34

think they've been successful in doing so.

19:36

All right . I understand. I just hadn't heard

19:40

the phrase tax equity

19:42

used. I've actually interviewed three

19:45

different folks involved in opportunity

19:48

zones, specifically in Puerto Rico, a couple of the

19:50

folks in the government and they've all

19:53

talked about that type of opportunity where

19:55

there's tax credits that are available that can be

19:57

swapped for investment in the

20:00

project. Okay. I get the idea. I just hadn't

20:02

heard the phrase used to describe it

20:04

before, which may have something to do with the fact that I don't do this a

20:08

lot.

20:08

Okay. Well I appreciate it. This is some really good stuff.

20:10

I want to find out a little bit more now

20:13

about Jon Talansky

20:15

the man and particularly

20:17

this economics and

20:20

philosophy BA from Columbia . Now I'm

20:22

going to tell you where my bias is, so

20:24

you know what you're walking into. I have

20:26

a bias. I have a bias

20:29

towards the value of the old

20:31

fashioned BA where folks were

20:34

actually kind of learning about

20:37

who we are as a people. And that's kind

20:39

of what a BA was.

20:42

And I know Columbia at least used to be one of those

20:44

places where you really could get that kind

20:46

of liberal arts education.

20:49

So with that in mind: economics

20:52

and philosophy. Got

20:54

a favorite economist and a favorite philosopher?

21:02

Good question. Well I did

21:04

pursue the Columbia degree for many

21:07

of the reasons that you're enumerating. I thought it was

21:10

at the time, important to pursue

21:12

a good grounding and a good

21:14

understanding of who we are and what we come from. And some

21:16

of the reading about some

21:19

of the great thinkers and philosophers that have really

21:21

informed Western thought.

21:25

I also was a college student

21:27

who was trying to figure out do I want to go

21:29

into this kind of career, that kind of career. And I thought economics

21:31

and philosophy was an

21:34

interesting combination to maybe expose

21:36

me to ideas that really ran

21:38

the gamut from one end of the spectrum to

21:40

the other. I had classes with the the MBA

21:42

types folks who were clearly headed towards

21:45

some sort of career in investment banking. And

21:47

then the philosophy classes with the

21:50

more cerebral types who maybe were already

21:52

with the plaid vest heading to

21:56

the professoriate . I did enjoy

21:58

my philosophy classes there. I think

22:01

I had a class called moral philosophy where we really

22:03

went through all the moral philosophers

22:05

in the great traditions in that area. I think philosophers

22:08

like Kant and David Hume are two that stick out

22:12

as philosophers whose general

22:15

worldview really piqued my interest and

22:18

got me interested in philosophy for some temporary period

22:20

of time. I think since then, tax law has really taken

22:23

up most of my time. I don't really have much time to read

22:25

philosophy on the side anymore.

22:26

Okay . So you've kind of gone more the Kantian

22:28

direction than the Humian direction.

22:31

Yes. I guess I

22:33

call myself a Kantian which

22:37

yes, I use the term very loosely. I probably

22:39

know less about Kant than anyone else who deems

22:41

themselves a Kantian. But yes.

22:43

Well, I mean, almost by definition if you're

22:45

involved in something as objectively,

22:49

theoretically objective as

22:51

tax law. That's not

22:54

David Hume's gig. That's,

22:56

that's definitely Kantian.

22:58

More categorical imperative. Yeah .

23:00

Yeah. So

23:05

what about what about the economic

23:07

side?

23:09

Economic side.

23:10

We can get you excited there still.?

23:14

You know what, I actually I found my undergraduate

23:17

economics degree a little bit

23:19

too far into the clouds for

23:21

my own liking. I guess I'm

23:23

a hands on straight to the point person. I

23:26

think the economics curriculum that, at least

23:29

in the 90s, what you got when I was at

23:32

Columbia, might not be what you'd get at

23:34

a more business oriented undergraduate

23:36

program, like a Wharton or a Chicago. The

23:38

classes were certainly interesting and put into

23:40

your head certain concepts of supply

23:42

and demand, labor economics, things like

23:44

that. But I can't really say that , um

23:48

my interest for example in tax law was really

23:50

piqued until I was in law school. Just really

23:52

focusing on the way the markets

23:54

work and just thinking more about practical

23:58

theories about the economy as opposed to the more

24:00

conceptual stuff. So I

24:04

certainly enjoyed my time there, but I can't say I walked

24:06

away hell bent on becoming some sort

24:08

of economist with a passion towards a particular

24:10

school of Economics.

24:11

Right. So how did you

24:13

decide on tax law? Did

24:16

you go to law school with that in mind

24:18

or was that a decision that you made while...

24:21

No, I made it in

24:23

, I guess you could say made it in

24:25

law school. I had a summer associate

24:27

position at a firm in New York and tried

24:29

my hand at t ax, did a little bit of litigation

24:31

work and t here was something I really liked

24:33

about tax a nd the fact that there's

24:37

an answer to most questions. There's

24:40

a right answer and a wrong answer. It's not

24:44

always... I think my grandfather once made a joke, he said, when

24:46

I look for a lawyer, I look for a one handed

24:49

lawyer. I said, why? He said, because every lawyer I ever

24:51

speak to says, well on the one hand this, and on the

24:53

other hand that. And I said, you know

24:55

what, that makes a lot of sense.

24:56

And you know, that resonated with

24:59

me and I think the rest is sort of

25:01

history. But I think that's why when I originally got interested in

25:03

tax low is because it's a

25:05

statutory body of law, there's a steep

25:07

learning curve, but as you build your knowledge

25:09

I think you just become more versatile and more

25:11

able to advise clients and think outside the

25:14

box. But with the fact being that there's

25:17

usually a structure that's most efficient that you can

25:19

get to . And there's something about

25:21

that that appealed to me and that continues to appeal to me,

25:23

which I suppose is why still

25:25

doing it this many years out.

25:27

Okay. That really makes a lot of sense

25:29

to me. And you know, if you think about the

25:32

world, and I apologize if we're getting

25:34

too esoteric here, listeners, but this is

25:36

stuff that I'm interested in. If you think about

25:38

that there's about half of humanity

25:41

views of the world through a Kantian lens and the other

25:43

half through a Humian lens. If

25:46

you are in fact the type of person who

25:49

feels like Kantian... Actually, that's

25:51

the wrong word. Who thinks like Kant rather

25:54

than feels like Hume, then

25:57

the particular kind of law you would guess

25:59

you'd go into would be something like tax law.

26:02

Where I would bet your

26:04

Humians end up in defense,

26:08

criminal defense.

26:10

Jack, I think you've just made more sense of

26:12

my trajectory from college to what I do today

26:15

than anyone else, including myself has ever made of

26:17

it. So I really thank you for that.

26:19

You're welcome. No charge. But

26:23

maybe I can get some kind of credit in the future.

26:27

Okay. Well, John, I appreciate the time. Your

26:31

expertise is obvious. And

26:33

frankly, as somebody who

26:35

makes a living with words, I love

26:37

how well you use the language. It's nice

26:39

to hear.

26:41

How do folks get a hold of you if they need or want

26:44

to know a little bit more about your

26:47

area of expertise, what's the best way to

26:49

contact you or King & Spalding ?

26:52

You certainly

26:54

can reach out to me by email.

26:57

It;s Jtalansky @kslaw.com . But

26:59

you can find me on the King and Spalding website

27:02

and then if you see a guy surrounded

27:04

by five loony kids, it's me with my five kids

27:06

surrounding me, pulling on every corner of me. So

27:08

that might be another way to find me, although I can't promise

27:10

that I'll have any attention to give to you.

27:13

You know, I had another interview earlier this morning with

27:15

a guy who had 10 kids, has

27:17

10 kids. We've

27:21

got 15 kids here in the interviews today.

27:25

Awesome. That's cool.

27:28

I appreciate it. Listeners, I will remind you

27:30

that the contact information for John

27:32

as well as for all of our guests will

27:34

be available on the podcast website. So if for some

27:36

reason you didn't manage to catch that, just

27:39

go to the podcast website and you can pick it up. Any

27:41

last words for us , John, before I let you go for the

27:43

day?

27:44

No, that's it. I hope everybody braves

27:46

the heat here if you're in the northeast and otherwise

27:49

I look forward to hearing from your listeners. And thanks for

27:51

doing this.

27:52

How hot is it today?

27:54

I dunno.

27:56

Tomorrow we're supposed to have a real feel of 110.

27:58

I'm here on Long Island. so I

28:00

certainly will be a huddled up inside.

28:03

Yeah . What is, what is "real feel"

28:05

translate into?

28:06

Don't know, never understood real feel and

28:09

wind chill, but I repeat it b ecause that's what I hear on 1010WIN, so

28:11

it sounds better.

28:12

Okay. Well if you come to Phoenix, you

28:15

will know exactly what 110 feels

28:17

like. A

28:19

ll right , well

28:21

for Jon Talansky of King

28:23

Spalding, I am Jack Heald for the OZExpo podcast.

28:26

Thanks for listening. Please go ahead

28:28

and press that subscribe button to get updated

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every time we drop a new interview. That happens

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