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Tax considerations when acquiring non-U.S. portfolio companies—mitigating subpart F inclusions

USA - July 17 2014 It is important for private equity purchasers to mitigate the creation of Subpart F income in structuring the acquisition and holding of the stock of…

Jeffrey C. Wagner, Thomas P. Ward

For private equity investors, Section 1202 may be worth another look

USA - March 21 2013 Included in the American Taxpayer Relief Act of 2012 (ATRA) are provisions that extended some of the more significant benefits of Internal Revenue…

Jeffrey C. Wagner

Year-end tax planning steps for private equity

USA - October 5 2012 The last time the Bush tax cuts were set to expire at the end of 2010, we saw numerous clients scrambling to execute end-of-the-year transactions designed to "lock in” the expiring tax rates.

The top five tax traps in M&A transactions

USA - August 31 2010 The tax consequences of acquisition and disposition transactions can dramatically impact deal value.

Jeffrey C. Wagner

Congress extends five-year carryback of 2008 or 2009 NOLs to most businesses

USA - November 10 2009 Congress has resurrected a prior Stimulus Act proposal allowing most taxpayers, not just small businesses, to extend the NOL carryback period under section 172 for up to five years for 2008 and 2009 NOLs.

Barry J. Quirke, Jeffrey C. Wagner