Tax Law

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Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers
Posted on 18 Dec 2012 by Pepper Hamilton LLP

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... Read More

Pepper Hamilton LLP Tax Update: New Chief Counsel Advice on Coordinated Acquisitions for Section 382 Purposes Raises Concerns
Posted on 26 Jul 2012 by Pepper Hamilton LLP

By Todd B. Reinstein , Partner, Pepper Hamilton LLP Section 382 limits a loss corporation's ability to use its tax net operating loss (NOLs) carryforward following an "ownership change."[1] An ownership change is triggered if one or... Read More

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers
Posted on 9 Apr 2012 by Pepper Hamilton LLP

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... Read More

Pepper Hamilton LLP Tax Update: Carried Interest Fairness Act of 2012 Retains Capital Gain on Enterprise Value
Posted on 30 Apr 2012 by Pepper Hamilton LLP

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP On February 14, 2012, Rep. Sander M. Levin (D-Mich.) again introduced legislation (H.R. 4016) to tax income from carried interests at ordinary rates. Taxing Carried Interests... Read More

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers
Posted on 9 Apr 2012 by Pepper Hamilton LLP

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... Read More

Pepper Hamilton LLP Tax Update: New Chief Counsel Advice on Coordinated Acquisitions for Section 382 Purposes Raises Concerns
Posted on 26 Jul 2012 by Pepper Hamilton LLP

By Todd B. Reinstein , Partner, Pepper Hamilton LLP Section 382 limits a loss corporation's ability to use its tax net operating loss (NOLs) carryforward following an "ownership change."[1] An ownership change is triggered if one or... Read More

Pepper Hamilton LLP Tax Update: Carried Interest Fairness Act of 2012 Retains Capital Gain on Enterprise Value
Posted on 30 Apr 2012 by Pepper Hamilton LLP

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP On February 14, 2012, Rep. Sander M. Levin (D-Mich.) again introduced legislation (H.R. 4016) to tax income from carried interests at ordinary rates. Taxing Carried Interests... Read More