Brian Allen

Brian Allen

Pepper Hamilton LLP

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Final Noncompensatory Partnership Options Regulations Could Affect the Tax Treatment of Penny Warrants and Other Arrangements

Investments in partnerships (and other pass-through entities such as limited liability companies treated as a partnership) often involve the acquisition of warrants, options or other rights to acquire securities. This is...more

7/7/2014 - Business Taxes IRS Limited Liability Companies Partnership Agreements Partnerships Pass-Through Entities UBTI

Foreign Tax-Exempt Organizations Exempt from Withholding Tax

Investment funds, including private equity funds, often receive capital contributions from tax-exempt organizations. These tax-exempt institutions may include U.S. and foreign pension funds, as well as U.S. and foreign...more

7/3/2014 - Colleges Corporate Contributions Foreign Charities Foreign Entities Investment Funds Pensions Private Equity Funds Public Charities Tax Exempt Entities Universities

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