FacultyFaculty/Author Profile
Annette M. Ahlers

Annette M. Ahlers

Pepper Hamilton LLP

Los Angeles, CA, USA

Annette M. Ahlers is of counsel in the Tax Practice Group with Pepper Hamilton LLP, resident in the Los Angeles office. She has more than 25 years’ experience providing large and mid-size corporate clients advice in corporate tax matters.

In addition, to her time at Pepper Hamilton LLP, Ms. Ahlers worked for the National Tax Group of Moss Adams LLP where she was part of the National Tax Practice as a tax partner, and 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’ work includes:

  • tax structuring and advising companies in M&A transactions
  • determining availability of net operating losses, including modeling for potential application of loss limitation provisions, and performing detailed multi-year studies documenting the existence or absence of an ownership change under these rules
  • tax issues associated with formation and liquidation of corporations
  • identifying capitalization and deduction opportunities for corporate transaction costs
  • working with clients in a post-merger context to obtain integration benefits
  • successfully applying for and receiving private letter rulings from the Internal Revenue Service
  • bankruptcy tax issues
  • debt vs. equity evaluations
  • spin-off transactions and corporate distributions.

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