Todd Reinstein

Todd Reinstein

Pepper Hamilton LLP

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Latest Publications


The IRS and Courts Weigh in on the Deductibility of Fines and Penalties - Tax Update, Volume 2016, Issue 3

Taxpayers who make payments in conjunction with a forfeiture action should attempt to understand the characterization of a payment to see if the specific payment can avoid being treated as a fine or penalty. Originally...more

11/22/2016 - Disgorgement Fines FINRA IRS Penalties SEC Section 162(f) Securities Exchange Act Securities Violations SRO Tax Deductions Tax Returns

Changes Coming to the Long-Term Tax Exempt Rate Used in Calculating Section 382 Limitations - Tax Update Volume 2016, Issue 1

Changes to the formula for determining the long-term tax-exempt rate used in a section 382 limitation calculation after a company undergoes an ownership change may lower the amount of net operating losses the company can use...more

6/7/2016 - Asset Valuations Business Taxes Change of Ownership IRS Net Operating Losses Tax Exemptions Tax-Exempt Bonds

A Look at Tax Issues of the Life Sciences and Tech Industries

Wolters Kluwer had the opportunity this past week to sit down with Pepper Hamilton LLP partners Todd Reinstein, Washington, D.C., and Joan Arnold, Philadelphia, to discuss current tax issues particularly relevant to the life...more

5/2/2016 - C-Corporation Foreign Corporations Intellectual Property Protection Life Sciences Net Operating Losses PFIC Pharmaceutical Industry R&D Tax Credits Technology Sector

Consolidated Return Update


8/27/2015 - Consolidated Tax Returns Filing Deadlines IRS Mergers Stocks Tax Returns Taxable Income U.S. Treasury

IRS Releases First Private Letter Ruling on Small Redemption Limitation

On October 21, 2013, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) issued Final Treasury Regulations to provide relief under Section 382 for small redemptions. These regulations provide taxpayer...more

3/2/2015 - IRS Net Operating Losses Private Letter Rulings Stock Redemption U.S. Treasury

IRS Issues a Field Service Advice on AMT NOL Ordering Rules

Section 172(b)(1)(A) provides that Net Operating Losses (NOLs) may generally be carried back two years and carried forward 20 years. The alternative minimum tax NOL cannot exceed 90 percent of alternative minimum taxable...more

11/12/2014 - Alternative Minimum Tax IRS Net Operating Losses

IRS Changes Course and Issues Notice 2014-58 on the Economic Substance Doctrine

The economic substance doctrine was historically a judicial doctrine. It was codified by the Health Care and Education Reconciliation Act of 2010 in Section7701(o). Although practitioners describe it as a codification,...more

11/12/2014 - Economic Substance Doctrine IRS Stock Sale Agreements Tax Avoidance

Rev. Proc. 2014-24 Provides Taxpayers Relief When Missing Form 1122 On Joining A Consolidated Group

On March 10, the IRS released Revenue Procedure 2014-24, establishing the rules for when the IRS will automatically determine that a subsidiary corporation that had failed to file a properly and timely executed Form 1122,...more

3/26/2014 - Consolidated Tax Returns Corporate Taxes IRS

Final Regulations Issued For Transfers Of Built-In Loss Property

On August 30, 2013 the Treasury Department released final regulations regarding guidance on Section 362(e)(2), preventing the duplication of loss when property containing a net built-in loss is transferred to a corporation in...more

1/16/2014 - Section 362 Tax Deferral U.S. Treasury

IRS Issues Favorable Final Section 382 Regulations On Small Shareholders; Might Be Time To Revisit Your 382 Study

The Treasury and IRS issued Final Treasury Regulations to address the treatment of small shareholders under Section 382 on October 21, 2013. These regulations address a number of concerns expressed over the years about the...more

1/16/2014 - Corporate Taxes IRS Net Operating Losses Shareholders U.S. Treasury

Recent Taxpayer-Friendly Section 199 Guidance On Benefits And Burdens Of Ownership

Section 199 allows a deduction equal to a percentage of a taxpayer’s income attributable to domestic production activities. For taxable years beginning in 2010 and thereafter, the deduction is generally equal to 9 percent of...more

9/4/2013 - Income Taxes Section 199 Tax Benefits Tax Deductions

New Regulations Provide Advantageous Acquisition Structures

New regulations issued by Treasury under Section 336(e) permit certain stock acquisitions to be treated as asset purchases, allowing buyers access to stepped-up asset basis and corresponding depreciation and amortization...more

7/17/2013 - Acquisitions Amortization Asset Purchaser Depreciation Mergers Section 336(e) Stock Options Tax Deductions U.S. Treasury

IRS Taking Tough Stand On Benefits And Burdens Of Ownership In Recent Section 199 ILM And Tax Court Cases

On April 1, the Internal Revenue Service (IRS) released ILM 201313020 (ILM) in response to an IRS Appeals Division request. It concludes that planning and development activities undertaken by a publisher of books and other...more

5/8/2013 - IRS Section 199

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