Annette M. Ahlers
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
- determining tax consequences of companies undergoing a bankruptcy or workout plan
- identifying capitalization and deduction opportunities as a result of corporate transactions
- working with clients in a post-merger context to obtain tax efficient structures for their U.S. and global operations
- successfully applying for and receiving private letter rulings from the Internal Revenue Service.
Ms. Ahlers is a frequent commentator on how new tax rules might affect a corporation’s tax positions and reporting obligations. Her recent publications include:
- “Recent Guidance on Post-Spin Payments Between Distributing and Controlled Companies,” published in Practical U.S./Domestic Tax Strategies (March 2010)
- “Four New Revenue Procedures Significantly Reduce the Reporting Burden Required by the Tax Shelter Rules for Certain ‘Ordinary Course’ Transactions and Events,” published at http://www.bnatax.com/tm/insights_Ordinary.htm, “Insights and Commentary” (December 2004)
- “New §6043A – Additional Administrative Burdens Required for Reporting of a Taxable Merger or Acquisition,” published at http://www.bnatax.com/tm/insights_Merger2.htm, “Insights and Commentary” (November 2004)
- “Tax Shelter Reporting Rules Now Carry a Heavy Price Tag for Noncompliance,” published at http://www.bnatax.com/tm/insights_Shelter.htm, “Insights and Commentary” (November 2004)
- “IRS Updates Tax Shelter List of ‘Listed Transactions’ and Penalty Assessment Procedures,” published at http://www.bnatax.com/tm/insights_Listed.htm, “Insights and Commentary” (October 2004)
- “Buying Assets Out of Bankruptcy – What You Don’t Know CAN Hurt You,” published at http://www.bnatax.com/tm/insights_Bankr.htm, “Insights and Commentary” (August 2004)
- “The Nuts and Bolts of Complying with the Tax Shelter Regulations” (co-author), published at http://www.bnatax.com/tm/insights_NutsandBolts.htm, “Insights and Commentary” (May 2004)
- “Important Modifications to Rules Governing Cancellation of Debts in a Consolidated Group” (co-author), published at http://www.bnatax.com/tm/insights_CODConsol.htm, “Insights and Commentary” (April 2004)
- “What is Ordinary and Necessary in an Extraordinary Business Cycle?” (co-author), published in Mergers and Acquisitions, The Monthly Tax Journal, Vol. 1, No. 9 (January 2001).
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.
Education
LL.M. 1992 Georgetown University Law Center
J.D. 1990 California Western School of Law
B.A. 1987 University of Washington
Bar Admissions
Admitted to practice in the District of Columbia and California
