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Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses that rob the U.S. Treasury."[1] Although most...

Tax Mitigation-Avoidance-Evasion

"Tax avoidance involves arrangement of a transaction in order to obtain a tax advantage, benefit, or reduction in a manner unintended by the tax law. It is an unacceptable manipulation of the law which is unlike legitimate tax mitigation. Mitigation involves use of the tax law to achieve anticipated...

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses that rob the U.S. Treasury."[1] Although...