Cut Unjustified Loopholes Act
Michigan Democratic Senator Carl Levin has introduced his proposed Cut Unjustified Tax Loopholes Act to target off-shore tax abuses.
In this podcast, Pepper tax partner Steve Bortnick, discusses how the act, designed to close a so-called loophole that allows foreign corporations to avoid paying U.S. taxes, might actually reduce U.S. tax revenues. Steve also discusses how this act would affect hedge and private equity funds.
If you are interested in the latest updates in the worlds of tax and private equity, you can request to receive an electronic copy of our monthly Tax Update newsletter or timely Funds Services client alerts by emailing firstname.lastname@example.org.
(Running Time: 12:08)
Distressed M&A Outlook - Market Conditions to Produce Significant M&A Opportunities
Recently Pepper hosted a breakfast discussion that was entitled “Distressed M&A Outlook - Market Conditions to Produce Significant M&A Opportunities.”
To gain perspective on the current distressed M&A market, Pepper Hamilton and Carl Marks Advisory Group commissioned mergermarket to survey a diverse group of corporate executives, private equity practitioners, hedge fund investors and lawyers regarding the foremost issues facing distressed investors today.
Moderated by Pepper partner Jim Rosener, this podcast features the panel discussion of Todd Feinsmith, partner from Pepper Hamilton, Warren Feder, partner from Carl Marks Advisory Group and Lawrence Klaff , principal from Gordon Brothers Group as they discussed the findings of our survey on the distressed M&A market and how the landscape has changed since the survey was conducted, including the Chrysler/GM effect, the imposition of politics on the financial markets and the repercussions of CIT.
Download a copy of the PPT slides from the event.
Stimulus Package: Buy Back Debt Today, Pay Tax Later
As market conditions continue to depress the value of outstanding debt, private equity funds and other debt issuers have the opportunity to acquire their indebtedness at significant discounts.
Pepper Hamilton attorney Steve Bortnick, a partner in the New York and Princeton offices and a member of the firm’s Tax Department, recently authored an article with fellow Pepper attorney Tim Leska titled “Stimulus Package: Buy Back Debt Today, Pay Tax Later.”
In this podcast, Steve discusses how the American Recovery and Reinvestment Act affects private equity funds and other debt issuers and discusses examples that he featured in his article.
If you are interested in the latest updates in the world of tax, you can request to receive an electronic copy of our monthly Tax Update newsletter by emailing email@example.com.
(Running Time: 11:22)
Pepper Hamilton Launches New Fund Watch Service
Developments in 2007 by Congress and the IRS are casting a long shadow over the tax treatment of private investment funds, their managers and sponsors. These developments occur often and change rapidly. The objective of the Fund Watch is to closely monitor all relevant developments in the area of fund taxation and to make this information available to you on a “real-time” basis.
In this podcast with Len Schneidman, of counsel with Pepper Hamilton’s Tax Practice Group and resident of our Boston office, he describes some of the developments that the Fund Watch will be monitoring in 2008.
If you would like to sign up to receive future electronic Tax Alerts on these developments, please e-mail Brian Dolan at firstname.lastname@example.org. You can contact our Fund Watch Hotline with specific questions on these issues by calling 866.333.0648 or e-mailing email@example.com.
(Running Time: 9:21)
Private Equity Insight: Dividend Recapitalizations
Pepper Hamilton and PricewaterhouseCoopers recently released a new study that presents findings from a survey of private equity firms. The study is entitled “Private Equity Insight: Dividend Recapitalizations” and was conducted in association with mergermarket, a research and publishing company.
Some key findings include:
• 97 percent of respondents expect to recapitalize portfolio companies in 2007
• the majority of dividend recaps will involve middle market companies
• most firms are comfortable with post-dividend recap leverage ratios
of 3.5 or 4 to 1.
(Running time: 5:47)
Private Equity Mezzanine Funds: Lenders or Investors?
The greatly increased activities of offshore hedge funds in the U.S. debt markets and the increased propensity of hedge funds to make loans have dramatically elevated the visibility of the “trade or business” status issue.
Listen to this short podcast with Len Schneidman, of counsel with Pepper Hamilton’s Tax Practice Group and resident of our Boston office, as he discusses this issue which has drawn the attention of the IRS and the popular press.
Len’s recently published book, U.S Taxation of Foreign Portfolio Investors, is the only professional book dedicated to the complex analysis of the critical U.S. and cross-border rules and regulations needed by foreign portfolio investors to minimize U.S. taxes on dividends, interest and trading gains. Please email firstname.lastname@example.org if you are interested in receiving a complimentary copy of the first chapter of his book.
(Running Time: 7:53)
The Controversy Behind Dividend Recaps
Private equity firms have turned to dividend recapitalizations in recent years to enhance returns on their investment and at the same time still maintain the future upside. While this financing technique is popular, dividend recaps are increasingly drawing fire from institutional investors, analysts, the media and legislators.
Why? Listen to a short podcast with Jim Epstein, a partner with Pepper Hamilton's Private Equity Group, who recently had an article published in The Deal on this interesting topic. During this podcast, Jim discusses the benefits and controversy behind dividend recaps.