About the Authors

Annette M. Ahlers is a partner in Pepper Hamilton LLP’s Tax Practice Group, resident in the Washington office. She concentrates her practice in corporate tax matters for large corporations.

Ms. Ahlers’ work includes: Structuring and advising on the tax aspects of corporate transactions; determining availability of net operating losses; assessing the reporting obligations under the tax shelter rules; and determining tax consequences of companies undergoing a bankruptcy or workout plan.

Ms. Ahlers is a frequent commentator on how new tax rules might affect a corporation’s tax positions and reporting obligations.

 

Ms. Ahlers joined Pepper in December 2004, from a national law firm, where she was the lead corporate tax partner. Before that she worked for nine years at Ernst & Young, LLP, where she was a national tax partner and director of M&A tax services for the mid-Atlantic area.

Ms. Ahlers started her career as an attorney-adviser in the Office of Chief Counsel (Corporate) of the Internal Revenue Service (1990 to 1994). Her responsibilities included drafting treasury regulations, private letter rulings, technical advice memoranda and other forms of guidance issued by the IRS. While at the IRS, she was the drafting attorney assigned to regulations under IRC Section 108 (nominal or token) and Section 382 (option attribution).

Ms. Ahlers received an LL.M. in taxation from Georgetown University Law Center in 1992, her J.D. from California Western School of Law in 1990, and a B.A. in economics and history from the University of Washington in 1987.

 

 

Todd B. Reinstein is tax a partner with Pepper Hamilton LLP, resident in the Washington office. Mr. Reinstein focuses his practice in three areas of tax law. The first area is advising clients on federal corporate tax law including the overall structuring of taxable and tax-free transactions, deemed asset purchases, shareholder redemptions, stock basis and earnings and profits calculations, eligibility for U.S. manufacturing deduction (IRC Section 199), simplifying corporate structures and minimizing the impact of complex consolidated return issues and tax due diligence. He also has significant experience with corporate loss limitation studies (IRC Section 382) and the tax aspects of bankruptcy and workouts, including issues involving restructuring or retirement of indebtedness.

Secondly, Mr. Reinstein is a member of the firm’s Sustainability and Climate Change Team. As such, he advises clients on structuring issues associated with claiming the credit for electricity produced from renewable resources (Section 45) and the solar investment tax credit (Section 48).

Thirdly, Mr. Reinstein advocates for taxpayers on federal (before the IRS Examination and Appeals levels) and international (Competent Authority Assistance) tax controversies, including collection issues. He has experience with submitting successful private letter ruling requests to the Corporate Branch of the IRS National Office. He also has experience representing associations and corporate taxpayers on complex federal tax issues through legislation and negotiations with the IRS. His experience in these controversies enabled him to achieve favorable and cost-effective results for clients.

Before joining Pepper, Mr. Reinstein was a senior associate in the corporate tax group of a national law firm. Before that, he worked for six years as a tax manager at two “Big 4” accounting firms. At the accounting firms, he advised domestic and foreign clients on tax planning, with a primary focus on acquisitions and divestitures, tax compliance and the financial aspects of accounting for income taxes. Mr. Reinstein also worked for three years as an internal auditor with the IRS, where he performed independent reviews and appraisals of various IRS operations, including the Appeals, Examination and Collection divisions.

Mr. Reinstein also has been a panelist at national meetings of the American Bar Association’s Tax Section and the Tax Executives Institute. Recently, he spoke on “Section 382: Traps for the Unwary” at the Tax Executives Institute’s 2008 Annual Conference in Boston, MA.

Currently, Mr. Reinstein serves as a Steering Committee member of the Tax Section of the Federal Bar Association. He also is a member of the AICPA Tax Division’s Corporations and Shareholders Technical Resource Panel and serves as an editor to The Tax Advisor monthly publication.

Mr. Reinstein is a member of the District of Columbia and Florida bars, and is admitted to practice before the United States Supreme Court, the U.S. Tax Court and the U.S. Court of Federal Claims. He is a licensed Certified Public Accountant in the District of Columbia and Maryland.