Steven Bortnick

Steven Bortnick

Pepper Hamilton LLP

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Anti-Inversion Legislation May Impact Non-Inverted Private Equity Deals

Corporate inversions have been the target of regulatory or statutory tax proposals for many years. However, the recently attempted combination of Pfizer and AstraZeneca received prompt and more far-reaching attention in the...more

7/25/2014 - AstraZeneca Corporate Governance Corporate Taxes Foreign Corporations Inversion Pfizer Subsidiaries

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

Proposed Carried Interest Legislation Takes A Different Approach

On February 26, 2014, U.S. Rep. David Camp (R-MI), chairman of the House Ways and Means Committee, released a draft of the Tax Reform Act of 2014 (TRA 2014), which would provide for the most significant tax reform since the...more

3/5/2014 - Business Taxes Capital Gains Corporate Taxes Income Taxes Tax Credits Tax Reform Ways and Means Committee

Choosing The Right Counsel For A Cross-Border Fund Formation

ABC Capital wants to set up a fund that will invest in a new asset class, and anticipates that the investors will be drawn from inside and outside the United States....more

8/22/2013 - Cross-Border

First Circuit Holds Private Equity Fund May Be Liable For Portfolio Company’s Pension Liability

On July 24, the U.S. Court of Appeals for the First Circuit held that two private equity funds managed by Sun Capital could be liable for their portfolio company’s withdrawal liability from a multiemployer pension plan (Sun...more

8/5/2013 - Employee Benefits Investment Portfolios Liability Multiemployer Plan Pensions Private Equity Private Equity Funds

Integrating Foreign Currency Hedges With Respect To Stock Purchase And Sale Agreements

Investment funds that invest globally must deal with volatility in the currency in which they agree to invest. Investment funds entering into obligations to purchase stock in a currency other than the primary currency of the...more

5/7/2013 - Currency Fluctuation Executory Contracts Hedges Income Taxes Integration Clauses Investment Funds Stock Purchase Agreement Stock Sale Agreements

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